With the Companies House transition period closing in mid-November 2026, this guide shows UK law firms, accountants and lenders how to check directors' and PSCs' identity verification status across a client book, and what to do with the gaps.
If you advise UK companies, the identity verification question has moved from "what is changing?" to "which of my clients are not ready?". Identity verification for directors and people with significant control (PSCs) became a legal requirement on 18 November 2025, with a 12-month transition for existing individuals that ends on 17 November 2026. A director ID verification check now belongs in every onboarding file, every deal checklist and every lending condition. This guide sets out who must verify and when, why the public register can mislead you, and a 10-step process for checking a whole portfolio before the deadline.
Where identity verification stands in October 2026
The Economic Crime and Corporate Transparency Act 2023 requires directors, PSCs and equivalents such as LLP members to verify their identity with Companies House. Each person verifies once, either through GOV.UK One Login or through an Authorised Corporate Service Provider (ACSP), and receives a personal code that is then linked to each of their appointments.
The scale is large. Companies House expects to have verified 6 to 7 million individuals by November 2026. By 31 March 2026, 3 million people had verified through GOV.UK One Login and 783,000 through ACSPs, according to its annual report for 2025 to 2026. Companies House management information for April to June 2026, as summarised by Law Debenture, showed that only 55% of directors and 42% of PSCs had told Companies House they had verified by the end of June.
Enforcement has started. The Insolvency Service has secured its first three convictions for failing to comply with identity verification requirements (reported in BCLP's October 2026 corporate briefing). Acting as a director without verifying is an offence, and a company that allows an unverified director to act also commits an offence, although the appointment and the director's acts remain valid, as Gowling WLG explains.
Who has to verify, and when
There is no single date for everyone. Due dates depend on the person's role, set out in the GOV.UK guidance (last updated 30 July 2026).
Existing directors
An existing director gives their personal code as part of the company's next confirmation statement. A director of several companies does this for each one, on each company's own timetable.
Existing PSCs
A PSC who is not a director must give their personal code within the first 14 days of their birth month. A PSC who is also a director provides the code separately for each role: as a PSC, within 14 days starting the day after the company's confirmation statement date.
Corporate PSCs
Where the PSC is a relevant legal entity, the entity must name a relevant officer, an individual whose identity has been verified. That is easy to miss in a group where the registrable owner is another company.
New appointments
New directors must verify before they act. A PSC added after 18 November 2025 can give their code when added or within 14 days. Verification for people who only file documents at Companies House is not expected before November 2027, according to Pinsent Masons.
Why the public register alone is not enough
It is tempting to search the register, see a reassuring status and move on. Three features of the regime make that risky.
The personal code is private. It does not appear on the public register, so a third party cannot cross-check it.
The register can lag reality. A company can only file its confirmation statement once all of its directors have verified. If only some have, the register may show that none have. Travers Smith's knowledge lawyers call this the "invisibility problem" in their May 2026 analysis for finance transactions, and suggest lenders also obtain a director's certificate confirming that every director has verified.
Timing varies by person. A client with a confirmation statement due in December has directors who are not yet late. A non-director PSC born in March may not be due until March. A flat "verified or not" report without due dates will produce false alarms and miss real ones.
The practical answer is to treat the register as your starting evidence, record its date, and pair it with due dates and, where a transaction depends on it, a written confirmation from the client.
Director ID verification check: a 10-step process for advisers
Before the deadline: build the list
- List every client company you act for or lend to, including dormant companies, SPVs and LLPs. Groups often have more entities than the engagement letter names.
- Pull current directors, members and PSCs for each company from the register, with appointment dates.
- Trace corporate PSCs upwards until every chain ends with an individual or a relevant legal entity with a named relevant officer. Our guide to mapping a UK group structure covers the method.
- De-duplicate people across companies. One person who sits on twelve boards is one verification, linked to twelve appointments. Chasing them once saves eleven emails.
- Note each person's due date: the confirmation statement date for directors, the birth month for non-director PSCs, and the appointment date for anyone added since 18 November 2025.
Reading the results
- Check verification status for every person and role, and save a dated record of what the register showed. In bulk, this is the job ProbeDigital's ECCTA director verification check is built for.
- Sort into three groups: verified, not yet due, and overdue. Only the third group needs urgent action.
- Read overdue cases in context. An unverified status can reflect the invisibility problem, a director who has resigned but not been removed, or a person who should not be on the register at all. It is a question to ask, not a conclusion.
After November: keep it current
- Build the check into onboarding and periodic review, alongside the ownership and control checks in your corporate client KYC checklist, and re-run it when officers or PSCs change.
- Put it in your deal and lending checklists: status of every director and PSC of the target or borrower, a dated register extract, and a director's certificate where completion or drawdown depends on it.
What to do when someone is unverified
For an existing client, the first step is usually a direct message with the due date and the two routes to verify: GOV.UK One Login, or an ACSP. If your firm is registered as an ACSP, you can verify the client yourself. Record the reminder on file.
For a new client or a counterparty, an overdue verification should raise the risk rating rather than end the conversation. Ask why, check whether the person still holds the role, and look at their other appointments: a pattern of unverified roles across several companies tells you more than a single gap. Where a director still has not verified after the transition, consider whether the company can file its confirmation statement, and what that means for your engagement or facility.
For regulated firms, the record matters as much as the check. The Money Laundering Regulations 2017 already require you to identify and take reasonable measures to verify beneficial owners. A dated verification check, the due date and your follow-up show a supervisor how you handled the gap.
FAQ
When does the Companies House identity verification transition end?
The 12-month transition that began on 18 November 2025 ends on 17 November 2026. Individual due dates within it depend on each company's confirmation statement date and, for non-director PSCs, their birth month.
Can I confirm a director's verification from the public register?
The register is a useful starting point, but it can understate verification where a confirmation statement has not yet been filed, and the personal code is not public. For transactions, pair a dated register check with a written confirmation from the company.
Is an unverified director's appointment invalid?
No. The appointment and the director's acts remain valid, but acting while unverified is an offence for the director, and the company commits an offence if it allows it.
Do people who file at Companies House need to verify too?
Not yet. Verification for filers is expected no earlier than November 2027.
Want to see the verification status of every director and PSC across your client book in one pass? Book a 40-minute demo, or sign up free and run your first check today.
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