Economic Crime and Corporate Transparency Act 2023: Identity Verification Becomes Mandatory From 18 November 2025

Companies House has announced that identity verification (IDV) for directors and individual controllers (PSCs) of companies will become mandatory from 18 November 2025. In summary, the requirements will apply immediately to all new director appointments and registrations of PSCs made from that date (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. Additional IDV requirements for other roles will follow at a future (unspecified) date.

This long-anticipated announcement marks the beginning of a step-change in the approach to the transparency of UK corporate vehicles, and those that control them, and is one of the most significant changes in the Economic Crime and Corporate Transparency Act 2023 (ECCTA) implemented to date.

What is ID verification

Our previous update and this Companies House Guidance explains identity verification and the IDV process in detail. In short, an individual is required to prove their identity using specified ID documentation and other personal details either via a free Government service or via an authorised third party provider. Once completed, the individual will receive a unique identity number (ID Number). This ID Number will then be used by the individual to link their verified identity to their various roles at Companies House.

IDV should, in most cases, only need to be undertaken once, but an individual is likely to have to provide their ID Number to Companies House on multiple occasions and so, when received, it should be kept safe and confidential.

Who needs to complete IDV, and when?

According to the Companies House announcement and revised Guidance, the following individuals will need to complete IDV and provide their ID Number in accordance with the following deadlines. But, as the commencement and transitional regulations and Companies House forms have not yet been published, it is possible some details may change.

New directors: anyone appointed as a director of a company from 18 November 2025, whether that is on the incorporation of a new company, 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 will need to provide their ID Number as part of the company’s next annual confirmation statement (CS01) filing. This will need to be done separately, by the relevant CS01 deadline, for every company of which they are a director.

Individuals becoming a PSC from 18 November: any individual who becomes a PSC from 18 November will need to provide their ID Number to Companies House within 14 days of being added to the Companies House register.

Individuals already registered as a PSC on 18 November: the deadline for existing PSCs 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 then again, as a PSC and via a separate online service, 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 same requirements will apply to members of limited liability partnerships.

It is clear from the above that individuals with more than one role will have multiple compliance deadlines.  From 18 November, individuals will be able to check the register at Companies House for the deadlines applicable to all of their roles.

It is worth noting that the compliance process for a PSC relies on the individual PSC taking action to notify Companies House of their ID Number via a separate online service and is not built-in to the company’s compliance obligations. Company secretarial functions in companies with individual PSCs may wish to ensure that those individuals are aware of these personal obligations.  

Future expansion of IDV requirements

As explained in our previous update, ultimately, the IDV regime will be more wide-ranging. Companies House have confirmed that IDV requirements for the following will be introduced at a later date:

• officers of RLEs (which are corporate entities classed as persons with significant control under the PSC regime);
• limited partnerships;
• corporate directors of companies;
• corporate members of limited liability partnerships; and
• any person filing documents or information at Companies House (other than a person filing under the authority of an authorised corporate service provider).

Changes to company registers

Companies House have also confirmed that the requirement for companies to maintain their own registers of directors, directors’ residential addresses, secretaries and PSCs will be abolished from 18 November 2025. Instead, from that date, the overarching requirement will be to ensure that the equivalent information is up-to-date at Companies House.

Companies will still be required to maintain their own register of members, and to keep this available for public view at their registered office (or single alternative inspection location), and the little-used ability for a company to elect to hold member information on the central register at Companies House (instead of in its own register of members) will be abolished.

Next steps

Although there are still a number of weeks before the IDV requirements become compulsory, because IDV is a one-off process, there is little to be gained in individuals delaying obtaining their ID Number until their first deadline approaches; we recommend starting now to ensure that any delays or problems are identified early, and well in advance of any deadline.

Help and previous updates

CMS have been helping clients prepare for the new regime since it was introduced on a voluntary basis in April this year, 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 with a member of the CMS team, please get in touch with your usual CMS contact.

For more on ECCTA, see our previous updates: 

• Economic Crime and Corporate Transparency Act 2023: Launch of the Identity Verification Regime (2 April 2025)
• The Economic Crime and Corporate Transparency Act 2023: Companies House publishes timetable for implementation (28 October 2024)
• Economic Crime and Corporate Transparency Act 2023: changes expected to come into force on 4 March 2024 (20 February 2024)
• Another step towards transparency: the Economic Crime and Corporate Transparency Act 2023 becomes law (8 November 2023)