Every company director in England and Wales must now have their identity verified by Companies House, and the 12-month transition period for existing directors runs out in mid-November 2026. This article sets out who is covered, how verification works, and what the first prosecutions reveal about enforcement.
What has changed for company directors?
Under the Economic Crime and Corporate Transparency Act, identity verification became a legal requirement for directors and people with significant control (PSCs) on 18 November 2025. Voluntary verification had been open since 8 April 2025, according to Companies House announcements published on GOV.UK.
New directors must be verified before they are appointed, or before they incorporate a company. Existing directors were given a transition period of about 12 months. Companies House has estimated that 6 to 7 million individuals will need to verify by mid-November 2026.
GOV.UK guidance is explicit that 18 November was “not a deadline”. It marked the start of the transition. The practical effect is that the pressure builds steadily and then lands at once, which is why autumn 2026 is the moment many boards are reviewing their paperwork.
Who counts, and when does each person’s clock run?
The rules differ by role:
| Role | When verification is due |
|---|---|
| New director | Before appointment or incorporation |
| Existing director | By the company’s next confirmation statement, within the transition period |
| New PSC | Within 14 days, starting from registration with Companies House |
| Existing PSC who is also a director | Within 14 days of the company’s confirmation statement date |
| Existing PSC who is not a director | Within 14 days, starting from the first day of their month of birth on the register |
Some categories, including limited partnerships, corporate directors, corporate LLP members and officers of corporate PSCs, are due to be covered later.
Each person’s date varies, and Companies House has said it is contacting companies directly. For a London firm with several directors, a PSC who sits outside the board, or an overseas parent-company officer, the dates may not line up neatly.
How does verification actually work?
There are four routes, according to the GOV.UK guidance:
- GOV.UK One Login online. The person needs a biometric passport from any country, a UK photo driving licence, a UK biometric residence permit or card, or a UK Frontier Worker permit.
- Bank or building society details online, where the service confirms eligibility. The person needs their National Insurance number and must answer security questions.
- A Post Office visit, after first entering photo ID details on the GOV.UK service.
- An Authorised Corporate Service Provider (ACSP), such as an accountant or solicitor supervised for anti-money-laundering purposes, which verifies on the person’s behalf.
The person also needs their current address and the year they moved in, plus an email address that has not been used for another verification, since each email can verify only one identity. Verifying online through Companies House is free of charge.
Expired documents are a common snag. Passports cannot be expired. A DVLA-issued driving licence can be used if it expired within the last 90 days, and residence permits and cards if they expired within the last 18 months. Expired documents cannot be used on the bank or Post Office routes.
What did the first prosecutions show?
On 17 September 2026 the Insolvency Service and Companies House announced the first prosecutions for identity verification offences. Three directors were fined at City of London Magistrates’ Court on 16 September 2026. The amounts are small, but the facts are instructive.
| Defendant | Company | Fine | Costs | Victim surcharge | Total |
|---|---|---|---|---|---|
| Jill White | White (Reading Properties) Limited | £166 | £85 | £66 | £317 |
| Marc Dillon | White (Reading Properties) Limited | £307 | £85 | £123 | £515 |
| Modinat Banjo | J Isogony Apparel Limited | £80 | £85 | £32 | £197 |
Across the three cases, fines come to £553, costs to £255 and surcharges to £221, a combined £1,029 (illustrative arithmetic from the published figures).
Two details stand out. Ms White verified only in early September 2026, about nine months after the requirement began, while taking part in board decisions and signing accounts. Mr Dillon had verified his own identity but was convicted for failing to take reasonable steps to stop the company acting while a fellow director was unverified. Ms Banjo, based in London, verified around 28 May 2026 and had signed and filed accounts before then. Each company was also convicted of failing to file confirmation statements on time.
Is a verified director enough to protect the board?
The Dillon case suggests not. Acting as a director without being verified is an offence, and the Insolvency Service’s announcement made clear that directors carry responsibility for not allowing an unverified person to keep acting. A board with one conscientious member and one laggard is therefore a shared problem.
This is a governance point as much as a compliance one. Boards that already keep a register of who signs what, and when, will find it easy to add a verification status. Those that run on informal arrangements, as many owner-managed businesses do, are more exposed. The same discipline that helps a firm understand its cash flow applies here: know the dates, know the owner of each task, and review them regularly.
Why enforcement may feel different from here
Companies House has said it will take a “proportionate approach to enforcement” and will help companies comply. The first fines were modest, and the court costs and surcharges made up a significant share of each total. But a conviction is a conviction, and the cases show prosecutors will pursue both the unverified director and colleagues who let the company carry on.
There is also a reputational angle. Banks, lenders and counterparties often look at the public register when deciding whom to deal with, so a late confirmation statement or an unverified director sends an unhelpful signal. For founders still working through the practical challenges facing new businesses in London, it is a small administrative task that can become a large distraction.
A checklist for the weeks before mid-November
Because the details vary by person, a simple internal review is the most efficient approach:
- List every director and PSC, including those who are not on the board but hold significant control.
- Check the Companies House register for each person’s identity verification due date for each role they hold.
- Confirm that each person has valid, unexpired photo ID and an unused email address.
- Decide whether individuals will verify themselves online or use an ACSP, which may suit directors who are overseas or have limited digital access.
- Make sure the personal code is available when the next confirmation statement is filed.
- Record completion in the board minutes or compliance file.
The wider small-business picture is already one of rising costs and thin margins, as covered in the broader view of how London’s business landscape is changing. A late filing or an offence is an avoidable addition.
What London boards should do with the remaining time
As of 10 October 2026, roughly five weeks remain of the transition period, going by Companies House’s mid-November estimate. Verification itself is quick and free online for most people. The risk lies in assuming it has been done, in forgetting a PSC, or in tolerating a colleague who has not yet acted. The first prosecutions suggest that those assumptions carry real consequences, and that the Insolvency Service is willing to pursue them. Companies that treat the task as a board-level item now, rather than as a filing-day afterthought, will avoid the scramble.
This article is general information, not legal, tax or financial advice. Rules and dates can change, so check current Companies House guidance for your own circumstances.
Sources: GOV.UK; Companies House; Insolvency Service
