Companies House Identity Verification: What Happens After the November 2026 Deadline
Companies House identity verification became a legal requirement on 18 November 2025 for directors and people with significant control (PSCs) of UK companies, and a 12-month transition period for existing office holders ends in mid-November 2026. Companies House told the market that the opening date was not a deadline in itself, but the end of the transition is the point where enforcement becomes realistic. This article explains who has to verify, what changes once the transition period closes, how non-resident founders can complete the process, what happens to unverified directors, and what to do in the days that remain.
Who Must Complete Companies House Identity Verification?
The rules apply to individuals, and they apply regardless of nationality or country of residence. A director based in Singapore or Dubai is covered in the same way as one living in London.
Directors and equivalent officers
Every director of a UK company must verify, as must the equivalents of directors: LLP members, general partners and managing officers of overseas companies registered in the UK. A director who has not verified is not allowed to act as a director, and the company cannot file its confirmation statement until all of its directors have a verified identity. Overseas companies with a UK establishment must confirm that their directors are verified by the anniversary of the establishment's registration.
People with significant control
Individual PSCs must also verify, even when they hold no board seat. A PSC who is not a director gives their personal code within the first 14 days of their birth month, so a person born on 22 January has a window that opens on 1 January. A PSC who is also a director supplies the code through the confirmation statement and then has a separate 14-day period starting the day after the confirmation statement date.
Roles not covered yet
Companies House has postponed verification for people who only file documents, corporate directors, corporate LLP members and officers of corporate PSCs, and the official guidance gives no date for them. The ICAEW reported in January 2026 that the filer requirements would not start before November 2026, and the gov.uk guidance now says only that they will arrive at a later date. If your structure includes a corporate director, expect that rule to reach you eventually.
What Changes When the Transition Period Ends in November 2026?
During the transition, a company that had not yet verified its directors could still file. Once it ends, the individual deadlines become the operative rule for every existing director and PSC.
The date itself
Sources disagree on the day. Law Debenture, an authorised corporate service provider, writes that the deadline is 17 November 2026, while many other advisers count 12 months from 18 November 2025 and give 18 November. The gov.uk pages describe the 12-month transition but do not name the final day, so plan to finish well before 17 November.
Existing directors and the confirmation statement
Existing directors provide their Companies House personal code as part of the company's next confirmation statement. This means the practical deadline depends on the company's confirmation statement date, and the statement cannot be filed until every director has verified. A company whose statement falls due in December, for instance, has until then, but a late verification by one director holds up the whole filing.
Existing PSCs and the 14-day window
PSC windows follow the birth-month or confirmation-statement rules above and are personal to each individual. The registrar has discretion to extend a PSC's due date by up to 14 days, and after two digital extension requests the matter goes to an examiner.
By the end of June 2026, according to figures that Law Debenture attributes to Companies House management information published on 30 July 2026, 55% of directors and 42% of PSCs had told Companies House they were verified. Those numbers suggest that a large group of office holders will still be unverified when the transition closes.
How Do Non-Resident Founders Verify Their Identity?
Non-UK residents have two routes, and the right one often comes down to which documents the person holds.
The GOV.UK One Login route
The direct route is the free "Verify your identity for Companies House" service built on GOV.UK One Login. It accepts a biometric passport from any country, a UK photo driving licence, and UK biometric residence permits and cards, and the applicant must also give their current address and the year they moved in. Expired passports are rejected, and the Post Office and bank-details options are described as available to people who live in the UK.
Where direct verification tends to fail
Founders from countries with older, non-biometric passports, or with only a national ID card, often cannot pass the document check. Law Debenture reports that rejected GOV.UK applications and unrecognized international documents are the typical reason clients turn to an agent. A person who has just moved or has an unusual name or address history also tends to need manual support.
When an agent route makes sense
An authorised corporate service provider can verify a client from any country, with no requirement to travel to the UK, and Companies House then sends the personal code to the email address the client gave the agent. Founders setting up a UK company registration from abroad often choose this route because the same provider can handle the incorporation and the verification together. For a founder who needs help with both, our corporate services team can coordinate the process.
What Are the Penalties for Unverified Directors?
Companies House has said it will use the full range of its powers, and its published enforcement approach describes how.
Filing blocks
The most immediate consequence is practical: the confirmation statement cannot be filed while any director is unverified. A company that misses its statement then faces the ordinary consequences of late filing, which include a growing risk of being struck off the register.
Offences and enforcement
Acting as a director without completing verification is unlawful, and the non-compliance guidance refers to section 167M of the Companies Act 2006 for continuing to act. The registrar can prosecute through the courts, refer a case to the Insolvency Service or impose a financial penalty, and prosecution may lead to a criminal conviction, director disqualification and fines. Companies House is likely to treat a case as serious where a person or company has committed three or more offences over five years.
Default letters and future sanctions
A missed deadline normally triggers a default letter. Representations made within the set time usually pause enforcement for up to two months. The guidance also lists further sanctions that are planned: a note on the public register, and a bar on being appointed as a director of another company, registering a new company or registering as an ACSP.
Directors who also run bank accounts for the company should note that a flagged register entry can feed into onboarding checks, a pattern we describe in our article on why banks freeze non-resident accounts.
How Does the ACSP Route Work?
An ACSP is a firm that has registered with Companies House as an authorised agent and can verify identities on behalf of clients.
What an ACSP is
To register, a firm must be supervised for anti-money laundering purposes, and it may be located in any country. The firm itself and its own people also have to verify their identity before they can register.
What the client provides
The client gives the agent a full name, home address, email address and evidence of identity. The agent carries out the checks and tells Companies House, which sends the personal code to the client's email.
Fees and the public register
The One Login route is free, while an ACSP is allowed to charge for its work. Companies House shows a verification statement on the public register that includes the person's name, the verification date, the ACSP's name and the names of its AML supervisors. Companies House has also said that businesses will later need to be registered as authorised agents to file on behalf of clients.
Checklist Before the Deadline
For a company with directors or PSCs abroad, the following sequence usually works:
List every director, LLP member and individual PSC from the register, with the confirmation statement date and each PSC's birth month.
Check which documents each person holds, and confirm that the passport is biometric and unexpired.
Send each person to the One Login service, or to an ACSP when the documents do not pass.
Collect each personal code and store it with the company records.
File the confirmation statement or PSC code only after every code is in hand.
Make a note of the 14-day PSC windows so that none of them closes unnoticed.
After the deadline, check the register for each person's status, and see our first steps checklist after registering a company for the wider housekeeping.
Final Thoughts
The transition period ends in mid-November 2026, and by then each existing director needs a personal code for the next confirmation statement, while each PSC needs one within their own 14-day window. An unverified director cannot lawfully act, the company cannot file its confirmation statement, and repeated non-compliance can lead to prosecution, a financial penalty or disqualification. Non-residents with a biometric passport can usually verify for free in a few minutes, and those with other documents typically need an ACSP, which may charge a fee.
Icon.Partners can help with identity verification for non-resident directors and PSCs, and with the UK company filings that depend on it.
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