ECCTA Update: What do I need to know about the new identity verification regime?
ECCTA Update: What do I need to know about the new identity verification regime?
In the first of our two-part update on the upcoming changes to be introduced as part of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), this article focuses on the new identity verification (IDV) requirements for directors, people with significant control (PSCs) and any other individuals who file documents at Companies House on behalf of UK companies. These new requirements will significantly change the information required and processes involved in incorporating and operating a company in the UK.
From 8 April 2025, Companies House has enabled individuals to voluntarily verify their identities. From autumn 2025 (the exact date is yet to be confirmed), Companies House will start a compulsory IDV check for all new incorporations and new individual appointments, with a transition phase of 12 months for all existing directors and PSCs to verify their identity when a company’s annual confirmation statement is filed. By spring 2026, it is anticipated that IDV for individuals who file documents at Companies House on behalf of UK companies will also be compulsory.
Who needs to have their identity verified?
The IDV regime impacts on:
company directors (and those with equivalent roles to directors in incorporated entities, such as LLP members, general partners and managing officers)
PSCs (these are individuals who own or control a substantial portion of a company) or relevant officers of a registrable legal entity (being a corporate body which would be considered to be a PSC if it were an individual)
anyone filing documents at Companies House on behalf of a UK company (e.g. a company secretary).
If IDV has not been completed by the required timeline, this may lead to an unlimited fine on the individual.
How do I get my identity verified?
Currently, identity can be verified voluntarily either by an authorised agent (these are professional service providers, such as solicitors and accountants who have registered as an authorised agent to be able to provide IDV to clients) or directly through Companies House. Wallace is not an authorised agent so is unable to assist with IDV.
There are three ways identity can be verified directly with Companies House using the GOV.UK One Login. The first step for each option is to create a GOV.UK One Login account; this can be done with an email address and a mobile phone so security codes can be received (Create your GOV.UK One Login or sign in - GOV.UK One Login).
GOV.UK ID Check’ App: click here for guidance on the app App Guidance
Individuals will need a suitable smart phone with a camera and one of the following types of photo ID:
o biometric passport from any country
o UK photocard driving licence (full or provisional)
o UK biometric residence permit or UK biometric residence card
o UK Frontier Worker permit
The App Guidance sets out the different steps you need to take depending on the photo ID used.
2. Web Service: Identity Verification Website
An individual will need to answer some security questions and enter details from either their UK passport, UK photocard driving licence or a current account with a UK bank (so the documents that can be used for this option are more limited than using the app option).
3. Face to face service at the Post Office
For those with a UK home address, an individual will need to enter one of the photo identification documents listed below on to their GOV.UK One account first, then book an appointment at a selected post office for an in-branch verification. The following types of photo identification can be used:
o UK passport or non-UK passport
o UK or European Union photocard driving licence
o National identity photocard from an EU country, Norway, Iceland or Liechtenstein.
Once identity has been verified with Companies House, a unique identifier code will be sent out to the verified individual. The code is personal to the verified individual and should be kept carefully as it will be required when making certain filings at Companies House. The code will also be used to connect verified ID documents to all of an individual’s appointments across all entities registered at Companies House, meaning identity should only need to be verified once.
What should I do now?
Ahead of the autumn, it would be advisable to work out which individuals in your organisation need to be verified, for each of them to set up their GOV.UK One Login and make sure that the identity documents are easily available (for example, if a passport renewal is due, consider getting the IDV done before the renewal process). As IDV can be carried out now, Companies House is encouraging those who need their identity to be verified, to do so now in the voluntary period and beat the potential rush when the IDV requirements become compulsory. If the IDV is not done during the voluntary period, we would suggest that you are aware of the annual submission date of your organisation’s confirmation statement so IDV can be completed ahead of the relevant filing date.
The above is intended to give a brief summary on upcoming ECCTA changes. If you would like further guidance or advice, please contact Sarah Merriott, Imogen Kelland or your usual Wallace contact.
