ECCTA IDV: the 12-Month Window Closes 18 November 2026 — Which Clients Are Still Unverified?

Mandatory identity verification at Companies House began 18 November 2025. 18 November 2026 marks one year — and for many existing directors on annual confirmation cycles, it is the effective final checkpoint. A practitioner checklist for identifying and clearing unverified individuals before their CS01 deadline arrives.

What the 18 November 2026 date actually means

There is no single "18 November 2026 deadline" that applies to all directors. The Economic Crime and Corporate Transparency Act 2023 created a per-company, per-CS01 obligation: existing directors and PSCs who were in post before 18 November 2025 must have verified their identity at or before the first CS01 the company files on or after 18 November 2025.

Companies with annual confirmation dates in autumn 2026 — October, November, December — are those whose first post-November-2025 CS01 is now approaching or imminent. For those companies, the window is functionally closing. By 18 November 2026, any company that incorporated in autumn 2024 or earlier and has not yet filed a post-November-2025 CS01 will be reaching its last chance to do so before the one-year mark.

Three related changes should not be blurred together when communicating with clients:

• Software-only accounts filing starts from 1 April 2028. That applies to accounts filings made to Companies House in commercial software using iXBRL; it is 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 a separate route. Individuals can still verify directly through GOV.UK One Login; ACSP identity checks are for registered authorised agents verifying someone else's identity.

Who you need to identify

The obligation sits with every individual who is a director or PSC of a company that has not yet filed a CS01 since 18 November 2025. That means:

• Directors and PSCs of companies with their first post-November-2025 CS01 coming up between now and December 2026.
• Directors and PSCs of companies that have already missed a post-November-2025 CS01 (where the filing was either rejected or the company is now overdue).
• Newly appointed directors and PSCs since 18 November 2025 — these individuals are subject to immediate verification; there is no transition grace period for new appointments.

The check is per individual, not per company. A director who sits on six boards verifies once, and the personal code is linked to their Companies House appointments. If one of your clients has already verified via GOV.UK One Login for one company, they do not need to repeat the process for a second company — but you should confirm the appointment position in the official Companies House or filing workflow rather than copying personal codes into PenaltyProof.

Practitioner checklist: clearing unverified individuals

1. Pull every client company's next CS01 date. This should come from your practice management system or the Companies House API. Sort by date ascending. Focus immediately on any company with a CS01 due before 31 December 2026.
2. For each company in that window, list every current director and PSC. The Companies House register shows officer appointments. You need each individual's name and appointment date.
3. Check the official Companies House or filing workflow. Use the source record to decide which appointments need a chase, then record only readiness metadata in PenaltyProof. Keep any personal-code handling inside your firm's controlled Companies House or ACSP process.
4. Contact unverified individuals now — not the week before the CS01. GOV.UK One Login verification requires a UK biometric passport or UK photocard driving licence plus a smartphone. Most UK-resident individuals can complete it in under fifteen minutes. Build the contact into a template you can send immediately.
5. Identify ACSP candidates. The ACSP route (via a registered accounting firm) is for individuals who cannot complete One Login: non-UK residents, those without accepted UK photo ID, or clients for whom verification is a billable professional service. ACSP registration has been available since 18 March 2025. Check whether your firm is registered if you intend to carry out ACSP verification.
6. For new incorporations and appointments from 18 November 2025 onwards, build verification into onboarding. There is no grace period. A director appointed today who is not verified cannot be named in a valid Companies House filing.
7. Confirm that filing software you use for CS01 supports verified submission. From November 2025, CS01s filed through the Companies House API require the verified personal code. Check with your software provider that this has been implemented.

What happens if an unverified CS01 is filed

Filing at Companies House while a required director or PSC is unverified — or causing an unverified person to be named in a filing — is a criminal offence under section 1112A of the Companies Act 2006. The Registrar's civil penalty regime can impose financial penalties up to £10,000 per breach under the Companies (Financial Penalty) Regulations 2024. In practice, the most immediate consequence is that the filing is rejected, which then causes the company's accounts and confirmation-statement calendar to cascade.

A rejected CS01 means the company immediately becomes overdue on its confirmation statement. Companies House can initiate strike-off proceedings against a company that fails to keep its confirmation statement up to date. Our guide to what happens when a confirmation statement is overdue covers the strike-off timeline.

The two verification routes

Direct via GOV.UK One Login (the default route)

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 linked to their Companies House appointments. For the majority of UK-resident directors with standard photo ID, this is the correct route. Verification is per individual — a director on multiple boards verifies once.

Via an ACSP (for individuals who cannot use One Login)

An Authorised Corporate Service Provider is an AML-supervised firm registered with Companies House to verify identities on behalf of clients. The ACSP route carries seven-year record-keeping obligations, prescribed checks under the regulations, and direct liability for incorrect verification. For practices with straightforward UK-resident client bases, directing clients to One Login is the simpler approach.

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. These are distinct from the IDV requirement but worth confirming to clients who query the CS01 invoice.

Monitoring tools and the CS01 calendar

The volume of per-company, per-individual checks is substantial for a practice with more than a handful of clients. A monitoring tool that surfaces every client company's next CS01 date, sorted by urgency, reduces the manual triage to a manageable daily or weekly sweep. See our guide on how to check Companies House filing deadlines in bulk, the related IDV transition guide for the autumn 2026 window, and the ECCTA identity verification and authorised-filer readiness deadline guide.