Guide for UK accountancy firms
Companies House identity verification: 12-month transition checklist
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Identity verification became mandatory for UK directors and persons with significant control (PSCs) on 18 November 2025 and is being phased in across a 12-month transition. This is a short, practical playbook for the firms doing the workflow.
1. The deadline most articles get wrong
The transition runs from 18 November 2025 to around 17 November 2026. The deadlines that apply to your clients are not the single November 2026 cliff edge that most coverage describes.
Each existing director and PSC must verify by their company's next confirmation statement date. If you act for 100 corporate clients, you have 100 sub-deadlines spread across the 12-month transition window. Each one comes with a 14-day birth-month window for the individual.
New appointees (directors taken on after 18 November 2025) must verify immediately on appointment.
2. The two verification paths
Identity verification is performed in one of two ways:
- Self-verification through GOV.UK One Login. Free for your client. Takes 5 to 15 minutes. Photo ID plus a short video selfie. Produces a Personal Code that is then linked to the individual's appointment.
- Via an Authorised Corporate Service Provider (ACSP). Your firm registers as an ACSP (£55 application fee at the time of writing). You perform the identity checks under that authorisation, issue the Personal Code through Companies House on the client's behalf, and bill for the work.
You can mix both paths across your client base. Some firms ACSP-route their corporate clients (because billable hours recover the cost), and let smaller clients self-verify.
3. The per-client workflow
For every active corporate client, repeat:
- Pull the current officer and PSC list from Companies House. Internal records are often outdated.
- Group your clients by their next confirmation statement date. Identify which deadlines are imminent.
- For each officer and PSC, decide: self-verify or ACSP-route?
- Communicate the deadline to the client. Include the specific confirmation statement date and the 14-day birth-month window.
- If self-verifying: walk the client through One Login. Ask them to forward you the Personal Code reference and the One Login confirmation email.
- If ACSP-routing: carry out the identity checks under your ACSP authorisation. Issue the Personal Code via Companies House.
- Record evidence of verification. Personal Code reference, One Login confirmation, ID copies (if applicable).
- Repeat for every new appointment as soon as a new director or PSC is taken on.
4. What to capture for your records
For each officer and PSC you should be able to produce:
- The individual's verification status (pending, in progress, verified)
- The Personal Code reference, stored in masked form. Never store the full code.
- The Personal Code expiry date. Codes expire and require re-issue.
- The One Login confirmation screenshot, if the individual self-verified.
- The ACSP record, if your firm performed the verification.
- Date of any chase emails or calls to the client.
- A note of which confirmation statement deadline the verification is linked to.
Companies House does not currently publish a per-individual verification status that you can query, so you need your own records.
5. After November 2026
The transition ending does not end the obligation. Identity verification becomes a permanent ongoing requirement. You will continue to:
- Verify every new director on appointment
- Verify every new PSC on registration
- Re-verify existing officers as required, typically after material changes or after a number of years
For that reason, the workflow you set up over the transition is the workflow you keep, not a 12-month sprint to be retired in November 2026.
6. Sources and further reading
Official sources:
- Companies House guidance on identity verification (GOV.UK)
- GOV.UK One Login
- ICAEW practice guidance on the Economic Crime and Corporate Transparency Act 2023 (members' area)
Companion guides on this site:
- ACSP registration explained - what an Authorised Corporate Service Provider is, when to register, what it costs.
- How to verify directors via GOV.UK One Login - step-by-step walk-through of the self-verification route.
- Confirmation statement deadline rules - how the per-client deadline is set and what the 14-day birth-month window means.
- PSC identity verification explained - how PSC verification differs from director verification, plus the corporate-PSC edge cases.
- Companies House Personal Codes explained - what the code is, how to store it safely, what to do when it expires.
The product:
Companies House data. Public sector information referenced in this checklist is made available under the Open Government Licence v3.0. RegisterTrack is not affiliated with or endorsed by Companies House, GOV.UK or any government body. This checklist is practical guidance based on published Companies House material, not legal advice. Firms should confirm the position with their compliance officer.