Companies House Identity Verification: Why Accountants Need to Act Now 

The Companies House identity verification reforms have moved into a new phase. 

Since 18 November 2025, identity verification has been a legal requirement for directors and people with significant control (PSCs). But the first prosecutions for failing to comply have now brought a more immediate message for directors and the professionals supporting them: identity verification is no longer something that can be treated as a future administrative task. 

On 16 September 2026, three directors were convicted in the first prosecutions for Companies House identity-verification offences. The Insolvency Service announced the cases the following day, warning directors that continuing to act without completing the required verification can lead to prosecution.  

For accountants, bookkeepers, company-secretarial teams and Authorised Corporate Service Providers (ACSPs), the development has a wider operational significance. 

Verification status now needs to be part of the compliance picture. 

The first prosecutions have changed the conversation 

The three cases involved directors who had failed to complete identity verification and continued to act as directors. 

One of the cases also involved a director who had verified their own identity but failed to take reasonable steps to prevent an unverified co-director from continuing to act. 

The cases also involved failures to file confirmation statements on time. 

The fines themselves were relatively modest, ranging from £80 to £307, but the significance of the cases is less about the amount of the penalties and more about what they demonstrate: the verification requirements are now being enforced.  

The Insolvency Service said that directors have responsibilities not only for their own compliance but also for ensuring unverified individuals do not continue acting as directors. 

That is an important distinction for practices managing company compliance on behalf of clients. 

It is no longer enough to tell a client that they need to verify their identity. Firms need a way of knowing who has verified, who has not, what needs to happen next and when the relevant filing is due. 

18 November 2025 was not a universal deadline 

One area that continues to cause confusion is the significance of 18 November 2025. 

This was the date on which identity verification became a legal requirement. It was not a single deadline by which every existing director had to complete verification. 

Companies House describes it as the beginning of a 12-month transition period. Existing directors are required to verify during that transition according to their individual circumstances and the relevant filing requirements.  

For directors, the key connection is the company’s confirmation statement. 

Companies House guidance states that directors need to provide their Companies House personal code as part of the company’s next confirmation statement. If someone is a director of multiple companies, they need to provide their code for each company.  

This makes the confirmation statement an important checkpoint for practices. 

Confirmation statements now have another dependency 

The operational impact is particularly important. 

Companies House states that a company will be unable to file its confirmation statement unless all its directors are verified. Directors also need to provide their personal codes as part of the process.  

That means a practice could have a confirmation statement prepared and ready to submit, but still be unable to complete the filing because one director has not completed the required verification. 

For firms handling hundreds of companies, that creates a very practical workflow question: 

How do you know which clients are ready to file? 

And perhaps more importantly: 

How early do you know which clients aren’t ready? 

Waiting until the confirmation statement is due could leave very little time to resolve an outstanding verification issue. 

What this means for accountants and company-secretarial teams 

The role of the accountant is changing from simply reminding clients about identity verification to managing it as part of the wider compliance workflow. 

Practices may want to consider keeping visibility of: 

• Which directors have completed identity verification  
• Which directors still need to verify  
• Companies House personal codes  
• Upcoming confirmation statement dates  
• Clients with multiple directorships  
• Changes in directors or PSCs  
• Clients who use an ACSP for verification  
• Any outstanding Companies House actions  

This does not necessarily mean creating another spreadsheet. 

The more important question is whether identity verification is visible alongside the other deadlines and tasks the practice already manages. 

For practices with large client portfolios, this could become particularly important as more companies move through the transition period. 

Personal codes are part of the process 

Verification itself is only one part of the process. 

When an individual successfully verifies their identity, they receive an 11-character Companies House personal code. The code belongs to the individual, rather than to a company.  

Directors use the code to confirm their verified status for each company where they hold a directorship. 

This means practices need to think about the practical administration around the code as well as the verification itself. 

Clients may complete verification but fail to provide their code to the person responsible for the company’s filing. 

That creates another potential point of friction. 

A simple client communication process can help: 

Verify → receive personal code → provide code → record status → complete filing. 

Don’t forget PSCs 

Identity verification isn’t limited to directors. 

PSCs are also required to verify their identities, although the timing and process differ depending on their circumstances. Companies House says PSCs generally have a 14-day period in which to provide their personal code, with the timing depending on factors including when they became a PSC and whether they are also a director.  

That means practices should avoid treating director verification and PSC verification as exactly the same workflow. 

For firms managing company compliance, having a clear distinction between the two will become increasingly important. 

What should practices do now? 

The first prosecutions provide a useful prompt for practices to review how they are managing identity verification. 

1. Review your client list

Identify companies where directors have not yet completed verification and where upcoming confirmation statements could be affected. 

2. Check personal codes

Where clients have verified, make sure the relevant personal codes are available to the person responsible for the filing. 

Personal codes should be handled securely and only shared with people the individual trusts to act on their behalf.  

3. Bring verification into your workflow

Don’t treat identity verification as a standalone reminder. 

Link it to the relevant confirmation statement, director appointment or other Companies House task. 

4. Contact clients before the deadline

If a director needs to verify, earlier communication gives them time to complete the process and resolve any problems. 

5. Review your internal responsibilities

Make sure your team knows who is responsible for checking verification status, requesting personal codes and confirming that a company is ready to file. 

6. Build it into onboarding

For new company clients, identity verification should be considered alongside the other Companies House and compliance checks rather than added later. 

The bigger lesson: visibility matters 

The first prosecutions demonstrate that Companies House identity verification has moved beyond being a future reform. 

For practices, the bigger issue is visibility. 

If a firm’s systems show confirmation statement deadlines but not whether the directors are verified, there is a risk of discovering a problem too late. 

And if identity verification can prevent a confirmation statement from being filed, it belongs much closer to the centre of the practice workflow. 

The firms that manage this effectively won’t necessarily be the ones sending the most reminders. They will be the ones that can quickly answer a few straightforward questions: 

Who needs to verify? 

Who has verified? 

Who has provided their personal code? 

Which confirmation statements could be affected? 

And what needs to happen next? 

The first prosecutions make those questions considerably harder to ignore. 

What this means for practice management 

As Companies House compliance becomes more interconnected, practices need a clear view of deadlines, client responsibilities and outstanding actions. 

A practice management system can help bring these tasks together, giving teams a central place to track work, deadlines, communications and client actions rather than relying on disconnected reminders and spreadsheets. 

For accountants managing identity verification across a large client base, the challenge isn’t simply knowing that the rules have changed. It’s making sure the changes become part of the day-to-day workflow. 

Source 

The Insolvency Service and Companies House announced the first prosecutions on 17 September 2026.  

For the latest official guidance, see Companies House: Verify your identity and Companies House: When you need to verify your identity.