Navigating ECCTA: Identity verification is now live

Under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) – the legislation adopted by the Government to reform company law and combat fraud and economic crime in the UK – certain individuals, including directors (both current and new appointees) and persons with significant control (PSCs) will be required to verify their identities.

Since our last briefing, which set out the proposed implementation timetable for ECCTA, Companies House has now introduced the identity verification (IDV) regime. Whilst the original dates outlined for the launch of Authorised Corporate Service Provider (ACSP) registration and voluntary IDV were initially postponed, both services are now available with ACSP registration opening on 18 March 2025 and voluntary IDV launching on 8 April 2025. Although IDV is not yet compulsory, companies may choose to take advantage of the voluntary service opening before IDV becomes mandatory (expected in Autumn 2025, although we do not have specific dates yet) and arrange for their directors and PSCs to complete IDV now. 

To support applicants completing the IDV process, the Government has published guidance setting out details of who must verify their identity and when IDV is required. The guidance includes the following ways an applicant can complete IDV:

IDV via Companies House

Verifying your identity directly at Companies House can be done free of charge using the GOV.UK One Login service, using documentation such as a biometric passport from any country or a UK driving licence. Applicants will need to answer questions on the Government’s portal to confirm their identity which can then be verified through the Government’s phone app or via a web browser.

IDV at a Post Office

Applicants living in the UK that cannot verify online may be able to complete the process in person using the “in branch verification” service offered by some UK Post Offices. At the time of writing, we understand this method will also be free of charge. Applicants will need book an appointment through the GOV.UK One Login service. This method allows applicants to take a photo ID to a participating Post Office to prove their identity.

IDV via an ACSP

Alternatively, applicants may use an ACSP to complete the IDV process on their behalf. ACSPs are likely to charge a fee for providing this service and not all firms that become ACSPs will offer IDV services.

Personal codes

Irrespective of the method used, each applicant will be given a “unique identifier” (a personal code) upon successful completion of the IDV process. This can be used by the applicant to take on subsequent appointments without completing further verification steps as it will link to the applicant’s existing Companies House account. The applicant can also use this code to connect their verified identity to Companies House records for each role that the applicant holds.

Companies House has indicated that it anticipates IDV to be a one-off process although re-verification may be necessary in limited circumstances, such as if an individual gets married and changes their name or if the registrar has reasonable cause to believe that the information or evidence relied on in relation to IDV is misleading, false or deceptive.

As mentioned above, the mandatory IDV regime is expected to be introduced in Autumn 2025, when existing directors will need to provide their personal code with the company’s confirmation statement and PSCs will be asked to file their personal code at the same time. If you are appointed as a director or PSC from Autumn 2025, you will be required to provide the personal code when you incorporate a company. 

What next?

Companies should take proactive steps to ensure all their directors and PSCs are aware of the IDV requirements and request those directors and PSCs check they have the acceptable forms of identification documentation to complete the IDV process. Directors and PSCs may wish to voluntarily complete the IDV process with Companies House now, as once IDV becomes compulsory, the volume of applications at Companies House may lead to delays in processing. The introduction of compulsory IDV will trigger a 12-month transition phase for existing companies where existing directors and PSCs (and those in equivalent roles) will be required to complete IDV when the respective company’s next confirmation statement is due. 

For more information on how to verify your identity, see the government guidance or speak to your usual Farrer & Co contact. We will continue to monitor developments in this area. 

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances.

© Farrer & Co LLP, April 2025