Companies House ID Verification Under the ECCT Act

Identity verification at Companies House became mandatory on 18 November 2025. Most of the guidance you'll find online is a rewrite of the press release. This is the version that tells you what to actually do for a working client book.

What the ECCT Act actually requires

The Economic Crime and Corporate Transparency Act 2023 inserted sections 1110A to 1110H into the Companies Act 2006. Short version: every director, every PSC, every LLP member, and eventually every person filing anything at Companies House on behalf of a company, must have a verified identity on the register.

Voluntary verification opened on 8 April 2025. Mandatory verification began 18 November 2025. From that date no newly-appointed director or PSC can take up the role without being verified at or before appointment. Filing while unverified is a criminal offence under s.1112A and attracts civil penalties up to £10,000 per breach under the Companies (Financial Penalty) Regulations 2024.

Who needs to be verified and by when

Three populations, three deadlines.

• New appointments from 18 November 2025 — verified at or before the appointment is filed.
• Existing directors, PSCs and LLP members: the deadline is the next confirmation statement (CS01) filed on or after 18 November 2025. For companies with a confirmation date in autumn 2026, that is autumn 2026. For companies with an early-year confirmation date, the window is already closing. It is per CS01, not a single universal November 2026 date.
• Anyone filing documents at Companies House as a third-party agent (authorised filers) must be verified — date to be confirmed by Companies House (no earlier than November 2026, per Companies House). Company secretaries are not required to verify unless they are also a director, PSC or filer.

Verification is per individual, not per company. A director of six companies verifies once. That single fact saves more time than any other piece of guidance in this post.

Verifying directly through GOV.UK One Login

Free, takes a few minutes, works for most people. The director hands over a passport or UK photocard driving licence through GOV.UK One Login, completes a liveness check, and walks away with a personal code that gets attached to every filing they're named on. This is the right route for the vast majority of directors.

Where it falls down: clients without UK photo ID, clients abroad with documents the One Login flow doesn't accept, and clients who simply won't do it themselves. That's where the ACSP route comes in.

Verifying clients as an ACSP

An Authorised Corporate Service Provider is an AML-supervised firm registered with Companies House to verify identities on behalf of others. Registration opened 18 March 2025. You apply, supply your AML supervisor reference, and accept the record-keeping obligations.

Should a 50-client practice become an ACSP? Honestly, probably not. ACSPs must retain IDV evidence for seven years, must apply prescribed checks, and carry real liability for getting it wrong. If your book is mostly UK-resident directors with passports, push them through One Login and keep your engagement letter clean. The ACSP route earns its keep where you've got a steady stream of non-UK directors, or where you genuinely want to charge for verification as a billable service.

Evidence and record-keeping obligations

If you verify through One Login, the record sits with Companies House and you keep nothing. Verify as an ACSP and you keep the underlying evidence for seven years, and you must be able to produce it on request: document images, the result of the check, the date, and the identifier issued.

The trap is treating verification as a one-off per company. It isn't. It's per individual, and the personal code travels with them. Don't re-verify the same director four times because they're on four boards.

Practical workflow for a 100-client practice

A workable sequence:

1. Run a list of every director and PSC across the book. Deduplicate by individual.
2. Email the unverified ones a One Login link with a deadline tied to their next CS01.
3. Flag the directors who can't or won't use One Login. These are your ACSP candidates, or your "please appoint someone who will" conversation.
4. At every CS01 review, check that every named person has a verification code. No code, no filing.
5. For new incorporations from 18 November 2025, verification is now part of the onboarding checklist, not a post-incorporation chase.

The PSC angle is the one most firms miss. Directors get verified because someone owns them in the engagement letter. PSCs often don't, especially family-trust PSCs or non-director shareholders. Read more on why PSCs must now verify and where firms get it wrong.

Penalties for non-compliance

Filing while unverified, or causing someone else to file while unverified, is a criminal offence under s.1112A CA 2006. The Registrar's civil penalty regime can also impose financial penalties up to £10,000 per breach under the Companies (Financial Penalty) Regulations 2024. Rejected filings create knock-on problems with the accounts and CS01 calendar. Our piece on how Companies House late filing penalties work covers the cascade that follows.

For the source-backed distinction between direct IDV, ACSP identity checks, authorised-agent filing, and software-only accounts filing, use the ECCTA identity verification and authorised-filer readiness guide.

One last point. Verification of corporate directors, LP general partners and officers of corporate PSCs is still deferred as of May 2026. If your client structure relies on a corporate PSC sitting above an unverified individual, don't assume that loophole stays open. The direction of travel is clear.