Companies House identity verification: what accountants must tell clients before the November 2026 deadline

Since 18 November 2025, identity verification has been a legal requirement for everyone who owns or runs a UK company. It is part of the Economic Crime and Corporate Transparency Act 2023, and it is the biggest change to Companies House compliance in a generation.

We are now most of the way through the 12-month transition period, which ends in November 2026. For many of your clients, the real deadline arrives sooner — it is tied to their next confirmation statement. This guide covers exactly who must verify, the dates that matter, and how to get a whole client base through the process without it consuming your practice.

What identity verification actually is

Each director and person with significant control (PSC) must prove who they are, once, either through GOV.UK One Login or through an Authorised Corporate Service Provider (ACSP) such as their accountant. Once verified, they receive a Companies House personal code — a unique identifier they keep for life and use for every role they hold in every company.

The important distinction: verifying is a one-off act by the individual, but the code must then be connected to each role — and that connection is where the deadlines come from.

Who must verify, and by when

The rules differ by role, and the PSC rules catch people out:

• New directors and PSCs (appointed on or after 18 November 2025): verification is compulsory as part of the incorporation or appointment filing. No code, no appointment.
• Existing directors: must provide their personal code in the company's next confirmation statement. A director of five companies does this five times — once per confirmation statement.
• Existing PSCs who are also directors of the same company: must provide their code twice — once in the confirmation statement (as director), and once more through the ‘Provide identity verification details for a PSC’ service, within 14 days starting the day after the confirmation statement date.
• Existing PSCs who are not directors: must provide their code within the first 14 days of their birth month. A PSC born on 22 March has a window of 1–14 March. The exact dates for each PSC are shown on the Companies House register.

The practical effect: although the transition period formally runs to November 2026, each client's effective deadline is their own confirmation statement date or birth-month window. Some of your clients will already be late.

How clients verify

Most people can verify themselves free of charge in about 10–20 minutes using GOV.UK One Login. They need one of: a biometric passport (any country), a UK driving licence (full or provisional), a UK biometric residence permit or card, or a Frontier Worker permit. Those without photo ID can usually verify using bank details and security questions, or in person at the Post Office.

The alternative is verification through an ACSP — an accountant, solicitor or formation agent registered with Companies House as an authorised agent — who checks the client's documents and verifies on their behalf.

The ACSP opportunity for your firm

If your firm is AML-supervised, you can register as an ACSP for a one-off fee and verify clients' identities yourself. Two reasons this is worth doing:

• Client demand. Plenty of clients — particularly older directors and overseas PSCs — will struggle with the app-based route and will gladly pay you to handle it.
• Future filing rules. Companies House has said that in due course only registered authorised agents will be able to file on behalf of clients. Registering now future-proofs the way your firm already works.

One caution: verification through an ACSP carries AML obligations — you must check documents properly and keep records. It is real compliance work, not a formality, so price it accordingly.

What happens to clients who do not verify

• The company cannot file its confirmation statement without the directors' personal codes — and a missing confirmation statement puts the company on the path to being struck off.
• Acting as a director without having verified your identity, once your deadline has passed, is a criminal offence for both the individual and the company.
• New appointments and incorporations are rejected without verified identities.
• Companies House has begun serving notices on suspected bogus directors and has made clear that fines and prosecution will follow for those who ignore the requirement.

Getting your client base through it: a checklist

1. Pull a list of every corporate client and its next confirmation statement date — that date is the firm's real deadline for each company's directors.
2. Identify PSCs who are not directors and check their 14-day birth-month windows on the register. These are the clients most likely to be missed, because nothing prompts them.
3. Write to all affected clients explaining what to do, with the GOV.UK link, and a date you need their personal code by — at least two weeks before the confirmation statement.
4. Decide whether the firm will register as an ACSP, and what you will charge for verification.
5. Collect personal codes securely. A personal code is sensitive personal data — treat it like a National Insurance number. Chase clients for it through your client portal rather than email, and track who has and has not responded so nobody reaches their confirmation statement date unverified.

This is exactly the kind of deadline-driven document chase Kontua is built for: Companies House dates on one calendar, automated reminders to clients, and a secure portal for the codes and documents they send back.

One more deadline to fold into the same client letters: most of these directors and PSCs are also Self Assessment clients. Our Self Assessment 2025/26 deadlines guide covers the January dates and penalties worth flagging at the same time.

The bottom line

Identity verification is not hard for any single client — 20 minutes with a passport. The risk for your practice is administrative: dozens of clients, each with their own deadline, most of whom will do nothing until chased. The firms that come out of November 2026 cleanly will be the ones that started chasing early and tracked it properly.