Economic Crime and Corporate Transparency Act 2023:  What to expect from the new identity verification regime

Identity verification ("IDV") is key to the successful implementation of the Economic Crime and Corporate Transparency Act 2023 ("ECCTA").  IDV under ECCTA is designed to ensure that people on the Companies House records are who they claim to be.  All new and existing directors and persons who have significant control over a company ("PSCs") (among others) must have their identity verified.  What we already knew under ECCTA was that IDV could be carried out by either Companies House itself, or by a person (called an authorised corporate service provider ("ACSP")) authorised by Companies House to do IDV (among other things). 

The Government has now released the regulations (Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025) ("IDV Regulations"), which make provision, as envisaged by the Companies Act 2006, for identify verification, ACSPs and unique identifiers.  The IDV Regulations together with the draft rules on IDV published by the Registrar of Companies (Registrar's Rules on Identity Verification) ("IDV Rules"), which prescribe the type of information needed to effect IDV, gives a greater understanding of what IDV will look like.

In this briefing we will look at the procedure for IDV, in particular highlighting the information and evidence likely to be required, and we will also give some suggestions on how you can prepare for IDV verification before the regime comes into force.

IDV is required from:

• all new and existing directors of UK companies;
  
  
• all new and existing members of UK limited liability partnerships ("LLPs") (if the LLP member is a corporate entity, all of the directors (or equivalents) of that corporate entity must verify their identity);
  
  
• all new and existing persons in the UK and overseas, who are PSCs of UK companies and LLPs; and
  
  
• anyone who delivers documents to Companies House on their own behalf, or on behalf of another, including an ACSP.

Once the IDV regime is in force, any person, before they can be appointed a director of a UK company, must have their identity verified and must obtain from Companies House a unique identifier which confirms that IDV has been successfully carried out on that person.

By the Autumn 2025, Companies House envisage that it will make IDV a compulsory part of incorporating a new company and for the appointment of new directors and changes to PSCs.  After that date, there will be a 12 month transition phase which will require existing directors and PSCs to verify their identity.  This process, it is envisaged, will happen as part of the annual confirmation statement filing.

New PSCs have 14 days after the formation of a company, or after the PSC has notified Companies House that they have become a PSC, to confirm to Companies House that their identity has been verified.  For Relevant Legal Entities ("RLE"), this period is extended to 28 days within which they must provide Companies House with the name of a verified relevant officer of the RLE (this will either by a director of the RLE (or their equivalent in other registrable entities)).

Direct verification with Companies House

Under the IDV Regulations, a person applying for IDV must provide:

• a valid email address (being an email address at which, in the ordinary course of events emails sent to it by Companies House would be expected to come to the attention of that person);
  
  
• a current residential address; and
  
  
• supporting documentary evidence as set out in the IDV Rules.

Individuals can complete IDV using the following routes:

• using the Gov.UK ID Check application;
  
  
• using the Government's One Login web journey: and
  
  
• at the Post Office.

In the first instance, where available, biometric or photographic evidence that can be compared against the individual must be provided.  Where biometric or photographic evidence is not available (for example if their country of citizenship does not issue a passport with a biometric chip) there is an exceptions route whereby ID documentation can be checked by a Companies House approved third party.

There is no set time period within which Companies House must determine an application and, in fact, Companies House can request further information and require the applicant to take other reasonable steps before any application is approved.  If approved, Companies House will provide the applicant with their unique identifier.

Verification by an ACSP

For an ACSP to carry out IDV the individual must provide the ACSP with the personal information and contact information (similar to that referred to above).  As regards ID evidence, this is predominantly the same as the ID evidence required for a direct verification using the GOV.UKID Check application. The difference here is that the ACSP takes responsibility for verifying the individual's identity.

If an ACSP is satisfied that it has verified an individual's identity, the ACSP may deliver to Companies House a verification statement.  The verification statement must:

• state the name of the individual to which the verification statement relates;
  
  
• state the date on which the ACSP was satisfied that the required personal information was true;
  
  
• include a statement that the ACSP has delivered or will be delivering at the same time as the verification statement, the following information:
  
  
  • the individual's date of birth;
  • the required contact information of the individual;
  • a description of the information and evidence which formed the basis on which the ACSP approved the individual's application; and
  • the ACSP's unique identifier.

Once Companies House has received all this information, Companies House must provide the individual with their unique identifier.

Companies House has published the following indicative timetable applicable to IDV:

• From 25 February 2025 – applications will open from persons wishing to be appointed ACSPs;
  
  
• From 25 March 2025 – individuals will be able to carry out their own IDV using any of the three facilities referred to above;
  
  
• By Autumn 2025 – IDV will be a compulsory part of incorporating a new company and for the appointment of new directors and changes to PSCs ("Impact Date");
  
  
• Within 12 months of Impact Date – IDV of all existing directors and PSCs to be completed; and
  
  
• By Spring 2026 – IDV of any person presenting documents on behalf of a company to be compulsory and any third party agents filing documents on behalf of a company to be registered as an ACSP.

• Group structure – carry out a pre-IDV regime audit to establish who in your business will need to be IDV verified.
  
  
• Contact details - make sure you have up-to-date contact details for all directors and PSCs.  In particular, if you PSCs based in overseas jurisdictions, who may be more difficult to contact.
  
  
• Training – ensure that your directors and PSCs are briefed and prepared for ECCTA and IDV.
  
  
• ID documents - establish whether directors or PSCs have the necessary ID documentation.
  
  
• Internal processes - set up internal processes now for IDV verification.