ECCTA identity verification and authorised-filer readiness

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) brings identity-verification duties for company roles and separate authorised-agent filing changes. 18 November 2025 starts the Companies House transition timetable; practices need company-specific tracking rather than a single universal deadline.

What is this filing?

Identity verification can be completed directly through Companies House using GOV.UK One Login or, where appropriate, through a registered Authorised Corporate Service Provider (ACSP). ACSP identity checks, authorised-agent filing, and software-only accounts filing are separate changes. Accounts filing moves to commercial software from 1 April 2028; non-accounts Companies House web filing remains supported.

When is it due?

New directors need to verify for incorporations and appointments from 18 November 2025. Existing directors verify ahead of the company confirmation statement filed during the transition period, and PSC timing depends on role and Companies House due-date rules. Businesses filing on behalf of clients must be registered as an ACSP no earlier than November 2026. Software-only filing applies to accounts filing from 1 April 2028.

What's the penalty for missing it?

Missing the applicable identity-verification or authorised-filing requirement can block or reject affected filings and may lead to enforcement or civil penalties. Treat each date as a source-backed readiness point, because director, PSC, authorised-agent, and accounts-software timing can differ.

What it actually costs

The practical risk is operational as well as financial. If an identity-verification or authorised-filing requirement applies and has not been met, the affected Companies House action may be delayed or rejected, leaving related accounts or confirmation-statement work exposed. Civil penalties and enforcement powers sit behind the regime, but the immediate practice problem is knowing which client, role, and filing route needs attention next.

Why this catches practices out

• Director, PSC, ACSP, authorised-agent filing, and software-only accounts filing changes are often collapsed into one ECCTA task, even though the dates and obligations differ.
• Company-specific transition dates can bunch around confirmation statements, so a practice-wide November 2026 shortcut is too crude for client planning.
• Personal codes, identity documents, and ACSP evidence belong in official Companies House or ACSP workflows, not in general deadline notes or reminder tools.

How PenaltyProof helps

PenaltyProof sends readiness reminders and records readiness metadata for configured ECCTA dates. It does not verify identities, act as or register a firm as an ACSP, file Companies House documents or verification statements, store or check personal codes, store identity documents or ACSP evidence, or confirm official verified status.

Frequently asked questions

How does a director verify their identity directly with Companies House?

Companies House says individuals can verify online with GOV.UK One Login if they have accepted photo ID and the required supporting details. The service also points people without those documents to other available routes. PenaltyProof can remind a practice about readiness dates, but the verification itself happens outside PenaltyProof.

Can accountants verify their clients' directors via ACSP?

Only a registered and approved ACSP can carry out Companies House identity checks for someone else, and the checks must meet the Companies House identity-verification standard. PenaltyProof does not register firms as an ACSP, perform identity checks, submit verification statements, or store identity evidence.

Is November 2026 a universal deadline for every existing director and PSC?

No. 18 November 2025 marks the start of the transition, not one universal deadline. Existing directors are tied to the company confirmation-statement timetable, and PSCs can have different 14-day periods depending on their role and Companies House register data. Use official due dates for each role.

What changes on 1 April 2028?

The announced software-only change is for accounts filing. Companies House says UK companies will need to file accounts in iXBRL using commercial software from April 2028, while web filing remains available for non-accounts filings such as confirmation statements and director updates.

Official sources

• GOV.UK: verify your identity for Companies House
• Companies House: identity verification rollout from 18 November 2025
• Companies House: Authorised Corporate Service Providers
• Companies House: accounts filing changes from April 2028

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