This guide is written for solicitors, trainees and law students in England and Wales.
Director identity verification is now a legal requirement at Companies House. Every current director and person with significant control must verify by 18 November 2026. For most companies the real deadline is sooner, because an unverified director blocks the next confirmation statement. One person who has not verified stops the whole filing.
Who is this checklist for?
Firms that file at Companies House for clients. Firms acting as company secretary. And any firm wanting its own directors sorted before the deadline.
It also suits anyone advising a company with an overseas board, a large board, or a statement due this autumn. Those are the three situations where this goes wrong.
The rules come from the Economic Crime and Corporate Transparency Act 2023 and started on 18 November 2025.
What are the two deadlines?
Firms keep quoting the wrong one.
18 November 2026 ends the transition period. It is the long stop for everyone in post before the rules started.
The next confirmation statement is the one that bites. A current director must verify before that filing goes in. A company with a statement due in September has weeks, not months.
Anyone appointed on or after 18 November 2025 must verify before Companies House records the appointment. New PSCs get 14 days from registration to supply their personal code.
Who has to verify?
| Role | Deadline | Notes |
|---|---|---|
| Director in post before 18 Nov 2025 | Before the next confirmation statement, and by 18 Nov 2026 | The filing fails without it |
| Director appointed on or after 18 Nov 2025 | Before the appointment is recorded | No verification, no appointment |
| PSC in post before 18 Nov 2025 | Before the next confirmation statement, and by 18 Nov 2026 | Deadline varies if also a director |
| PSC registered on or after 18 Nov 2025 | 14 days from registration | Personal code must reach Companies House |
| LLP members | As for directors | Same regime |
| People who present filings, including agents | No earlier than November 2026 | ACSP registration required to file |
| Corporate directors, corporate LLP members, officers of corporate PSCs, limited partnerships | Later | Not yet in scope |
A PSC is, in most cases, anyone holding 25% or more of the shares or voting rights. Location makes no difference to any of this. An overseas director must verify like everyone else.
Which route should a person use?
There are two, and the choice usually turns on the individual rather than the company.
GOV.UK One Login. Free, and most cases take a few minutes with a biometric passport or a UK driving licence. It accepts biometric passports issued anywhere.
An Authorised Corporate Service Provider. An ACSP is a UK firm approved by Companies House to check identity. It must sit under one of the UK’s 25 anti-money laundering supervisors, which many law firms and accountants already do.
Use an ACSP for overseas directors, non-standard documents and large boards. Those are the cases where One Login stalls on camera quality, text codes or document checks.
Either route produces a personal code. That code, not the check itself, is what gets used at filing.
The personal code is the part firms underestimate. It belongs to the individual. Every filing needs it. And the person holding it is rarely the person doing the filing. A code sitting in one partner’s inbox is a single point of failure across every client company that partner touches.
The checklist
1. List every client company with a confirmation statement due before 18 November 2026. Sort by date. That list is the actual workload.
2. For each, list the directors and PSCs. Mark who has verified and who has not.
3. Flag the hard cases early. Overseas directors, anyone without a biometric passport or UK driving licence, and boards of more than four or five people. These take weeks, not minutes.
4. Decide the route per person, not per company. A board can mix One Login and ACSP verification without any problem.
5. Collect personal codes into one controlled place. Not an inbox. Codes are personal data tied to an individual, so store them the way the firm stores other client identity material.
6. Record a verification statement for each role. Someone who has already verified does not repeat the check. They must still supply the code and a statement for every role they hold.
7. Bring forward the confirmation statement where the board is already done. A company can file at any point in its review period. Filing early closes the issue.
8. Confirm the firm’s own ACSP position. It matters both for checking clients and for filing on their behalf once the presenter rules commence.
9. Diarise the presenter deadline. Companies House first expected it in spring 2026 and has moved it to no earlier than November 2026. Registration is open now and there is no reason to wait.
What happens if a director does not verify?
The filing fails first. Companies House will not take a confirmation statement while a director is unverified. It can also reject other filings and block new appointments.
Beyond that sit real penalties. Companies House has said it will issue civil penalties. Where a breach continues it will bring criminal charges. In the worst cases it can apply to strike the company off the register.
For a firm acting as company secretary, that is a client-facing risk. A missed confirmation statement shows on the public register, and the client will see it before the firm explains it.
What if a director cannot or will not verify?
Separate the two, because they need different answers.
Cannot is usually a technical problem and usually solvable. The passport is not biometric. The camera will not read the document. The text code never arrives. An ACSP handles all three, because a person can attend and be checked rather than fighting an app.
Will not is harder. There is no workaround and no discretion. The confirmation statement cannot be filed, and the consequences fall on the company rather than on the individual refusing.
That turns a compliance problem into a governance one. If a director will not engage, the board faces a choice between a blocked filing and a change of director.
Raise it early either way. A resignation and replacement takes time, and the replacement must verify before Companies House will record the appointment. Discovering that four weeks before a filing deadline is not a good position.
Common mistakes
Working to November instead of the confirmation statement. The long stop is not the operative date for most companies.
Assuming overseas directors are outside the regime. They are not, and they are the slowest cases.
Losing the personal code. The check is a one-off. The code is needed every time.
Forgetting the 14-day PSC rule. It runs from registration and is much shorter than the director timetable.
Leaving ACSP registration until the presenter rules commence. A firm that files for clients cannot keep doing so without it.
Official sources
Companies House runs guidance on its identity verification campaign site. ICAEW has published a briefing on ACSP registration and ID verification.
The Legal Brief covered the deadline in its news piece. It set out the wider economic crime agenda in its report on AML supervision moving to the FCA.
Last updated: 1 August 2026. This page will be revised when the verification requirement for people who present filings is given a commencement date.