New directors and persons with significant control (PSCs), and members of limited liability partnerships (LLP) are now required to verify their identity with Companies House. Existing directors have a 12-month transition period until November 2026 in which to complete the verification. 

What ID is viable?

Companies House is encouraging directors, PSCs and LLP partners to use one of the following forms of identification to verify themselves:

• a biometric passport from any country;
• UK photo driving licence (full or provisional);
• UK biometric residence permit;
• UK biometric residence card;
• UK frontier worker permit.

Along with this, they will need their current address, the year they moved in and a gov.uk One Login account. They can verify using other forms of identification, but it will take longer and will require more supplementary information.

Most directors and PSCs should be able to do the verification directly with Companies House and may just need reminding. However, there will be some who will need more support, such as those without biometric passports or newer driving licences. For example, some family businesses have elderly directors. In this case, clients might need help submitting their ID.

In that case, they might require verification by an ACSP (Authorised Corporate Service Provider). Accounting firms can register to provide these services as an ACSP.

Firms considering offering ID verification services as an ACSP

Offering ID verification (IDV) services will require firms to follow specific standards and procedures as set out in Companies House guidance. If you are going to provide these services, you will need the necessary in-house expertise to provide that service. Compared to Money Laundering Regulations checks, which are risk-based, IDV checks must follow a prescribed, step-by-step procedure.

If you fail to comply with the standards, Companies House can remove you from the ACSP register, which will mean you will no longer be able to file accounts on behalf of your clients. If you lose your ACSP status, any clients you have previously registered will also have their verification removed.

Smaller firms may decide that the risks are too great and instead partner with a verification service for those clients who cannot or do not want to use the self-verification option.

To register as an ACSP, you must be supervised by a UK anti-money laundering (AML) supervisory body, such as ICAEW (ICAEW doesn’t necessarily supervise ICAEW members or regulated firms, so be sure to check).

You will be required to supply specific and accurate details about your firm to Companies House. This includes its name, address and email, as well as your company number if you’re a limited company, the name of your AML supervisory body and your AML membership number or ID.

As the requirements under the AML regulations are not the same as those for carrying out IDV, simply fulfilling AML supervision requirements isn’t enough.

The ACSP ID verification process

Firms that register as an ACSP can conduct verification for their clients. They will need to meet the Companies House ID verification standard to conduct ID verification; this is a six-step process. Here are the steps as laid out in Companies House guidance:

1. Information gathering

Collect their full name and any former names they might have, date of birth, home address, 12-month address history, and their email address.

2. Review documents

Review their ID documents and make copies. The copies will need to be kept for seven years from the date ID checks are completed, but don’t need to be submitted to Companies House. Instead, ACSPs need to send the document number, expiry date and country of issue (if there is one).

There are two options for checking these documents. The first uses ID document validation technology (IDVT) to validate the cryptographic features of biometric or machine-readable documents.

If this isn’t available, the ACSP can use option two, which involves manual checks. In which case, the ACSP can either review two photographic ID documents, or one photographic and one non-photographic one, such as a birth or marriage certificate. A full list is published on gov.uk.

3. Check for false documents

In-person checks will need to be completed by someone trained in detecting false documents and familiar with the guidance on detecting forgeries. So it’s likely that there will be some training requirement for the individuals at the firm charged with completing ID checks.

4. Check the ID is of a real person

Ensure the person matches the photo on their ID, which can be done in-person or remotely. If they do not provide information to confirm their address history for 12 months, or if they’ve changed their name, additional documents should be asked for. Check documents, such as bank statements, council tax bills or insurance documents, that show the person’s home address.

5. Keep records of the checks

Records should be kept for seven years, this includes the copies of the documents, evidence of the identity checks and records of any failed ID checks.

6. Make a decision

Based on the information collected, decide whether they can be verified to the standard laid out in Companies House guidance. Then inform Companies House, providing the person’s details, the documents used to verify their identity (with details) and confirmation that checks have been completed to the standard.

ID verification checks are policed and enforced by Companies House, but firms should recognise the AML risks associated with being an ACSP. This is less of an issue for clients who are well known to the firm, but for new clients, it is worth questioning why an individual might come to the firm for an IDV check when about 97% of all checks can be done through self-verification.

What happens if a verification deadline is missed?

Existing directors and PSCs have a 12-month transition period to verify their identity. If they have not had their identity verified by the end of the transition period, they will not be able to operate as a director or PSC, or file with Companies House, until they have been verified. If they continue to operate as such while being unverified, they will have committed an offence and may be subject to fines and penalties.

Communicating the changes with clients

At this stage, all firms should be communicating the need to verify with Companies House and the consequences of not doing so.

ICAEW has created guidance for directors and PSCs to help them to self-verify. Firms can use their own experiences in registering their partners as a case study for clients to follow.