We have a date - Identity verification and statutory register reforms

Identity verification

On 18 November 2025, Companies House will introduce compulsory identity verification for all individual directors of UK companies and persons with significant control (PSCs).

At the same time, we expect ID verification to be introduced for individual members of UK limited liability partnerships (LLPs) and directors of overseas companies with UK establishments.  The recent announcement does not expressly say this but it would be consistent with previous communications.

Who needs to verify and when?

New directors appointed on or after 18 November 2025 must verify their identity before notifying Companies House of their appointment.  For new companies, first directors must verify before incorporation.

New LLP members admitted on or after 18 November 2025 must verify their identity before notifying Companies House of their admission.

Existing directors and LLP members must verify their identity before the due date for filing the next annual confirmation statement.  Their personal verification code issued by Companies House must be provided with the filing.

PSCs must verify within a 14-day period, the start date of which varies depending on their circumstances:

‍Individual directors of overseas companies with UK establishments must also verify their identity. For new appointments to the registered overseas company on or after 18 November 2025, they must verify before notifying Companies House of their appointment.  For existing directors, they must verify during a transition period starting on 18 November 2025 and ending on the first anniversary of the date the UK establishment was opened. Note that this regime is different to the UK’s Register of Overseas Entities, which requires overseas companies (whether or not they have a UK establishment) to disclose certain interests in registered land in the UK to Companies House.

How to verify

Identity verification can be completed online, in person at a Post Office or through an Authorised Corporate Service Provider (ACSP). For more information on this process, the evidence required and consequences of not complying, see our detailed overview and In Focus page.

Additional information

• An individual with multiple roles (e.g. both a director and PSC) must verify by the earliest applicable deadline. From 18 November, they should be able to check the Companies House register for ID verification due dates across all roles.
• Once verified, the verification is valid for all roles held by that individual. Verified individuals will receive a personal code for future filings.
• Until an individual’s identity is verified, acting as a director, LLP member, or director of an overseas company in relation to the affairs of its UK establishment, will be a criminal offence. Companies and LLPs (and their other officers/members) may also be liable. Amongst other things, this could impact decision-making, board meetings, and document execution. We recommend that individuals voluntarily complete their ID verification as soon as possible.
• Identity verification requirements for limited partnerships, corporate directors, corporate LLP members, and officers of corporate PSCs will be introduced in later phases.

Statutory register reforms

From 18 November 2025, companies will no longer have to create or maintain statutory registers of:

• Directors
• Directors’ residential addresses
• Secretaries
• PSCs.

This means that from that date, companies will only have to create and maintain a register of members (shareholders), register of charges created before 6 April 2013 and register of allotment of debentures.

While maintaining a fuller set of registers can be time consuming, many companies choose to do so on a voluntarily basis.  For example, registers of share allotments and transfers are not legally required for UK companies but are often still created.  They help to track share movements not always apparent from Companies House public filings – which can be very useful during M&A due diligence, for example.

Central register to be discontinued

Private companies will no longer be able to hold member information on the central register at Companies House.  Companies who have previously elected to use the central register must create and maintain their own register of members, and clearly record the period during which the central register was used.

Recommended actions

To prepare for these reforms, we recommend the following steps:

• Map out who needs to verify (directors, PSCs and LLP members).
• Identify upcoming deadlines, particularly confirmation statement due dates.
• Check PSC birth dates are correct to accurately calculate their verification deadlines.
• Gather the required ID documents based on Companies House guidance.
• Choose the most suitable verification route for each individual (online, in-person or ACSP).
• Encourage voluntary ID verification before November to avoid delays.
• Develop secure processes for collecting and storing verification codes (e.g. with your company secretarial team).
• Update internal policies to reflect new verification, appointment and admission requirements.
• Review and update shareholder registers, and transition from the central register if applicable.
• Monitor updates for future phases (e.g. ID verification for corporate directors and members).

These reforms represent a significant change in UK company law. Proactive planning will be essential to ensure compliance and avoid disruption.

If you have any queries or need support, please do get in touch or refer to our Economic Crime and Corporate Transparency hub.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at August 2025. Specific advice should be sought for specific cases. For more information see our terms & conditions.