Companies House IDV Transition: the Autumn 2026 Window Is Now

Mandatory identity verification at Companies House started 18 November 2025. Most existing directors haven't verified yet. The window closes at the next confirmation statement — and for companies with autumn confirmation dates, that is now.

What has happened since November 2025

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) made identity verification (IDV) a legal requirement at Companies House from 18 November 2025 (gov.uk, verifying your identity for Companies House). From that date, any newly appointed director or PSC must verify their identity at or before the point of appointment — no verification code, no valid appointment.

For existing directors and PSCs who were in role before 18 November 2025, the obligation kicks in at the company's next confirmation statement filed on or after 18 November 2025. There is no single universal "November 2026" hard deadline for all existing directors: the deadline is per company, per CS01 cycle. A company with a confirmation date in January 2026 should already have verified its directors. A company with a September 2026 confirmation date has its window open now.

The autumn 2026 urgency

Around half of UK companies incorporated between October and December have confirmation dates in that same quarter. If your book is typical, a large proportion of your clients' existing directors will have their first post-November-2025 CS01 falling between September and December 2026 — this autumn.

That means the practical deadline for many portfolios is not some distant event: it is the CS01 you are due to file in the next three to six months. If directors have not verified, the filing will be rejected. A rejected CS01 means the company is immediately non-compliant, and Companies House can initiate strike-off proceedings.

The two practical actions are:

1. Pull a list of every client company's next confirmation date. For each company with a confirmation date before 31 December 2026, identify every director and PSC, check the official Companies House or filing workflow for the role's IDV position, and record only readiness metadata in PenaltyProof.
2. Contact unverified individuals now — not two weeks before the CS01. The GOV.UK One Login verification process is free and takes around ten minutes for most people with UK photo ID. Build the chase into your onboarding and deadline tracking workflow.

How verification works

There are two routes, and most directors should use the first.

Direct verification via GOV.UK One Login

Free, available at gov.uk, and requires a UK biometric passport or UK photocard driving licence plus a smartphone camera. The individual completes the process online, receives a personal code, and that code is automatically linked to all their Companies House filings. For the majority of UK-resident directors with standard photo ID, this is the right route. Verification is per individual, not per company — a director on ten boards verifies once.

ACSP route (via a registered accounting firm)

An Authorised Corporate Service Provider (ACSP) is an AML-supervised firm registered with Companies House to verify identities on behalf of clients. ACSP registration has been live since 18 March 2025. A regulated accountancy practice can register as an ACSP and carry out IDV checks on clients who cannot or will not go through the One Login process — typically non-UK residents, clients without accepted UK photo ID, or clients for whom verification is a billable professional service.

The ACSP route carries record-keeping obligations: seven years' retention of verification evidence, prescribed checks under the regulations, and direct liability for incorrect verification. It is not a light undertaking. For practices with straightforward UK-resident client bases, the better approach is to direct clients to One Login and keep the practice out of the verification chain altogether.

What is changing, and what has not been decided

Three things are important to keep separate given the volume of speculation online:

• Software-only accounts filing now has a date. From 1 April 2028, accounts filings made to Companies House must use commercial software in iXBRL format. That is an accounts-filing route change, not a rule that every Companies House filing goes through verified software.
• Authorised-agent filing is scheduled no earlier than November 2026. Companies House guidance says authorised agents will be able to file on behalf of clients from no earlier than November 2026, and businesses will need to be registered as ACSPs to file on behalf of clients from no earlier than that date.
• Direct IDV remains separate from ACSP work. Individuals can still verify directly through GOV.UK One Login. An ACSP route is for registered authorised agents carrying out identity checks on someone else's behalf.

The fees since February 2026

Separately from IDV, Companies House increased its filing fees from 1 February 2026: the CS01 online fee rose to £34 (previously £13), and incorporation fees increased to £50 for same-day service and £100 for same-day assured. These are distinct from the IDV requirement but are worth confirming to clients who are surprised by the CS01 cost increase.

CATO (the joint Companies House and HMRC online filing service) closed on 31 March 2026. Companies can still use the filing routes that Companies House makes available for the relevant filing type; accounts filing has its separate software-only change from 1 April 2028.

Penalties for filing while unverified

Filing at Companies House while unverified — or causing an unverified person to be named in a filing — is a criminal offence under section 1112A of the Companies Act 2006 and attracts civil penalties up to £10,000 per breach under the Companies (Financial Penalty) Regulations 2024. In practice the more immediate consequence is a rejected filing, which then causes the company's accounts and confirmation-statement deadlines to cascade. Our ECCTA identity verification deadline page has more on the enforcement regime.

Practical checklist for the next three months

• Pull every client company's next confirmation date from Companies House API or your practice management system.
• For each company with a confirmation date before 31 December 2026, list every director and PSC by name.
• Check the official Companies House or filing workflow for each appointment's IDV position, and keep only readiness status, target date, source, and review metadata in PenaltyProof.
• Send a clear, dated communication to every unverified individual asking them to complete GOV.UK One Login verification and follow your firm's controlled Companies House or ACSP process for any personal-code handling. Do not paste personal codes into PenaltyProof.
• Flag ACSP candidates: non-UK residents, individuals without accepted photo ID, or clients willing to pay for assisted verification.
• For any new incorporations or appointments from 18 November 2025 onwards, verification is a prerequisite — build it into the onboarding checklist.