The compliance window is closing in November 2026
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced the largest change to UK corporate transparency in a generation. From April 2025 onward, identity verification at Companies House moved from optional to mandatory in stages. New director appointments and PSC registrations have required verified identity since November 2025. The 12-month transition window for existing directors and Persons with Significant Control (PSCs) closes on 18 November 2026. Miss it and the consequences are not theoretical: criminal liability, civil penalties up to GBP 10,000 per breach, and a public Companies House annotation that the director is not verified.
What identity verification actually produces
Verification is not a single tick box. It generates a documentary trail that the company itself, not just Companies House, must be able to reproduce on request:
- The Personal Code (Authorised Corporate Service Provider reference) issued after verification, which must be quoted on every future filing
- Evidence of the verification method used (GOV.UK One Login or ACSP route)
- The supporting identity documents reviewed (passport, driving licence, biometric data hash)
- Date of verification and details of any re-verification when documents expire
For PSCs, the trail is heavier still. The 25 percent shareholding declaration, the chain of beneficial ownership through holding companies, and any nominee arrangements all need backing documentation that maps to the verified individual.
Why this hits document management directly
Three operational issues catch UK companies off guard:
1. Authorised Corporate Service Providers (ACSPs) become record gatekeepers. Most companies use accountants or company secretarial firms as ACSPs to verify directors. The ACSP keeps the original verification evidence for at least seven years. If you change ACSP, you need a clean handover record. Otherwise the company loses the ability to demonstrate verified status.
2. PSC change events trigger re-documentation. Every share transfer, beneficial ownership restructuring, or nominee replacement requires fresh ID verification of the incoming PSC and updated supporting evidence. Companies that only update the PSC register without retaining the verification artefacts fail audit.
3. The annual confirmation statement now references verification status. Filing the CS01 with an unverified director listed will be rejected from late 2026. Companies need a tracked log of verification expiry and renewal dates.
The penalties you should price into the compliance plan
ECCTA gives Companies House new investigative and sanctioning powers. The headline figures:
- Failure to verify by the deadline: civil penalty up to GBP 10,000 per individual
- Filing a return on behalf of an unverified person: criminal offence, summary conviction up to 12 months
- False or misleading verification information: up to 2 years imprisonment
- Director disqualification: Companies House can seek disqualification of directors who consistently fail filing duties
Beyond the fines, the reputational cost of a director appearing as unverified on the public register affects bank account renewals, supplier KYC checks, and procurement bids. Several UK banks now treat unverified directors as a flag for enhanced due diligence under the Money Laundering Regulations.
What companies should do between now and November 2026
The remaining six months are not long given the queues at GOV.UK One Login and the manual nature of ACSP onboarding. A practical compliance sequence:
- Inventory every director, PSC, and authorised filer (including agents) attached to UK entities in the group
- Map who has already verified, who has started, and who has not begun
- Decide route per individual: GOV.UK One Login for UK residents, ACSP for overseas directors who cannot use One Login
- Centralise the Personal Code register in a controlled document repository, not in email inboxes
- Set re-verification reminders for ID documents expiring within 24 months
- Update the company secretarial process so that no Companies House filing is submitted without confirming all named individuals show as verified
The companies that handle this badly will spend Q4 2026 in remediation mode. The companies that treat the verification artefacts as a structured record set, retained alongside board minutes and statutory registers, will pass audit and avoid the penalties.
