What business owners need to know about new Companies House requirements – Bernadette Young, Co-founder and Director of Indigo Independent Governance, provides some guidance.
From today, (18th of November 2025), all UK directors are subject to new mandatory identity verification requirements. The new obligations are being phased in over the next year, with some directors impacted immediately and others with a little more time to comply.
It is not just directors who are going to be subject to the new regime. Persons with Significant Control (PSCs), meaning shareholders with more than 25% ownership or voting rights in the company or some other form of significant influence or control, are also covered by the new Companies House requirements. At a later date, 
other groups, including members of Limited Liability Partnerships (LLPs), corporate directors and officers of corporate PSCs, as well as individuals who file documents at Companies House, for example, company secretaries, will also need to have their ID verified too.
With literally millions of individuals across the UK falling into one or more of these categories and only a small proportion believed to be ahead of the game with voluntary registration before the deadline, the exercise to comply now needs to be begin in earnest.
How will the ID verification work?
Each individual captured by the new requirements will need to register with Companies House to confirm that their ID has been verified.
Once a person’s identity has been verified, it is then confirmed to Companies House which will issue a unique personal code to that individual. Each individual should only register once and will retain their personal code for life, meaning they are able to use it for as many appointments as they hold, now or in the future. It is important therefore that, once issued, the personal code is retained securely for future reference.
Who currently needs to have their identity verified at Companies House?
Whilst it is sensible that Companies House is taking a phased rather than a big bang approach to the introduction of the new registration requirements, it does mean that there is more risk of confusion about who needs to register in the initial wave and what deadline specifically applies to each person.
Dealing with directors first, any directors appointed to an existing company or on the formation of a new company after the 18th November will need to provide their personal code when they are appointed or the company is set up. For those who might take on new directorships or who may need to incorporate new entities from time to time, it is useful to already have their personal code available to minimise the risk of delays to the company formation or appointment process.
For existing directors, personal codes will need to be provided within each company’s next confirmation statement. For those with directorships across multiple businesses, separate companies are likely to have different confirmation statement filing dates. This is something to watch out for.
For PSCs, the position is different again. If a company’s PSC is also a director, despite already having registered the director’s personal code as part of the company’s confirmation statement, he or she will have to register for a second time for the same company as a PSC but using the same personal code. That second PSC registration should be completed within 14 days of the relevant confirmation statement date using a separate Companies House service.
For PSCs that are not company directors, the deadline for them to register their personal code at Companies House is the 14th day of the month in which they were born. So, for someone who is a PSC but not a director with a birthday in April, they will need to register by the 14th April.
New PSCs must register within 14 days of the company completing the relevant PSC filing at Companies House.
The table below summarises the current implementation deadlines.
| Circumstance | Deadline to register personal code at Companies House |
| Director appointed after 18th November 2025 | Required on appointment |
| Director of an existing company | To be filed with the company’s first confirmation statement that falls due after 18thNovember 2025 |
| Existing PSC who is also a director of the company | To be registered at Companies House within 14 days of the company’s first confirmation statement that falls due after 18th November 2025 |
| Existing PSC who is not a director of the company | To be registered at Companies House within 14 days of the start of the month of their next birthday (starting December 2025) |
| Individual who becomes a PSC after 18thNovember 2025 | To be registered at Companies House within 14 days of the company’s PSC filing |
What do limited company directors and PSCs need to do now?
Although the phased introduction of the registration requirements means that working out personal deadlines may be relatively complicated, getting organised now so that businesses are prepared for when those deadlines arrive is easy to do. Companies House are already issuing personal codes to those who have confirmed their ID verification has been completed.
Verification can be undertaken in a number of ways, including through the Government website or at a Post Office, or using an expert Authorised Corporate Service Provider (ACSP). Indigo: Independent Governance is one such ACSP. Alongside its convenient and secure ‘id to go’ smart phone biometric identity verification system, it is also able to offer in-person verification for those who lack the necessary biometric documentation such as a passport with a biometric chip.
Crucially for bigger groups of companies or external advisers with large numbers of people to process through the system, firms like Indigo should be able to efficiently project manage and coordinate the whole process to take the pressure off busy internal teams who are unlikely to want to add resource just to cope with this one-off exercise.
What ID documents are needed?
Ideally individuals are able to use biometric documentation, but they will also need a second document to confirm their address. This could be a driving licence, recent bank statement, utility bill or other official correspondence.
Changes of name and recent changes of address may mean additional documentation is required.
For those who lack an appropriate biometric identity document, in person verification is likely to be required. UK post offices are offering this service but for residents overseas, this is unlikely to be a feasible option and the services of an ACSP will be needed.
What are the consequences for companies and individuals who don’t comply?
Companies will be unable to file their confirmation statement unless they have all the personal codes of their directors to enable them to submit a completed form. This is considered a criminal offence, and directors can be fined up to £5,000 or even disqualified from being directors where they are repeat offenders. There is also the risk that the company itself will be struck off the register as a result.
Whilst Companies House will not be prosecuting individuals who fail to comply during the first year of the new requirements, this should not be taken as a signal to ignore the matter. It is a relatively simple to complete the process, albeit you need to work out when your compliance deadline is, and a job well worth ticking off the list.
For more information about Indigo’s board, governance and company sectorial services, visit: https://indigogovernance.com/