Economic Crime and Corporate Transparency Act 2023: Identity verification became mandatory from 18 November 2025

Companies House has announced that from 18 November 2025 identity verification (IDV) for directors and people with significant control (PSCs) of companies is mandatory. In summary, the requirements apply from 18 November 2025 to all new director appointments and registrations of PSCs (whether that is on the incorporation of a new company or as a change to an existing company) and will be phased in over 12 months for in-post directors and existing PSCs. A person with significant control is someone (there can be more than one) who owns or controls a company. A PSC is usually anyone who has more than 25% of the shares or voting rights in a company. For more detailed guidance please see here.

What is ID Verification, and how to do it

IDV should be a one-time process. So, for example, an individual holding multiple directorships, or who is both a director and a PSC (as may be the case for cast and crew loan-outs, or SPVs set up for production purposes), will only need to have their identity verified once. In short, an individual is required to prove their identity using specified ID documentation (such as a passport) and other personal details either via the free Government service here or via an authorised third party provider. Once completed, the individual will receive a unique identity number (ID Number) which is then used by the individual to link their verified identity to their various roles at Companies House. This ID Number should be kept safe as it will likely have to be provided to Companies House on multiple occasions.

Who needs to complete IDV, and when

New directors: anyone appointed as a director of a company from 18 November 2025, whether that is on the incorporation of a new company (for example, a new SPV set up for production purposes), or as a new appointment to an existing board, will need to provide their ID Number as part of the incorporation or appointment process.

Existing directors: directors in post on 18 November 2025 (for example, cast and crew with existing loan out arrangements, and existing production companies) will need to provide their ID Number as part of the Company’s next annual confirmation statement (SC01) filing. This will need to be done separately, by the relevant CS01 deadline for every company of which they are a director. As verification is a one-time process, we recommend completing the verification as soon as practicable, on a voluntary basis.  This is preferable to waiting until the relevant deadline, in case complications arise, due to, for example, details at Companies House not matching ID documents because of a change of name, use of a maiden name, expiry of ID documents, any mistakes in the original Companies House filings or information at Companies House being out of date.  Additionally, more time may be needed to complete IDV for individuals who are foreign nationals or are resident overseas.

Individuals becoming a PSC from 18 November 2025: any individual who becomes a PSC from 18 November will need to provide their ID number to Companies House when they are first added to the Companies House register, or within 14 days of being added.

Individuals already registered as a PSC on 18 November 2025: the deadline for existing PSCs (for example, cast and crew with existing loan out arrangements and existing production companies) to provide their ID Number to Companies House will depend on whether the PSC is also a director of the company which they control.

• where a PSC is also a director of the same company: the individual will need to provide their ID Number to Companies House twice – once as a director (on the company’s CS01), and again as a PSC via a separate online service here within 14 days of that company’s confirmation statement date.
• where a PSC is not a director of the company they control: the individual will need to provide their ID Number to Companies House within the first 14 days of the month of their birth. So, for example, if a PSC’s birthday is 25 December, they will need to provide their ID Number to Companies House by 14 December 2025.

The Companies House guidance on the process is here. If you are an individual with multiple directorships or PSC roles, you will have multiple compliance deadlines, which you can check at Companies House. Please note, however, that the PSC compliance process relies on the individual PSC taking the above actions to notify Companies House of their ID Number and it is not built into the company’s compliance obligations.

What are the consequences of failing to IDV

The IDV regime introduces a number of new criminal offences for failure to comply. These offences are not only committed by the relevant individual, but in certain cases can also be committed by the relevant company and its other officers. For example, an individual will commit an offence if they act as a director of a company without being ID verified by the relevant date and, because the company will also be under an obligation to ensure that no individual acts as a director without being ID verified by the relevant date, the company and every officer in default will also commit an offence. Companies House approach to non-compliance with mandatory ID verification can be found here.

Next steps

CMS have been helping clients prepare for the new regime, guiding them through the IDV process using either the Government pathways or referring to specialist verifiers where necessary. If you would like to discuss the above, please get in touch.