The IDV countdown is on! Directors, are you ready to verify your identity with Companies House?

Tackling economic crime, enhancing corporate governance and improving the integrity of the information on the register at Companies House are key Government aims, and the role of the Registrar and Companies House is expanding to give them the tools to tackle and achieve these objectives. The Economic Crime and Corporate Transparency Act 2023 (ECCTA) is part of a legislative package that is aimed at preventing the abuse of corporate structures, improving the accuracy of information on the public register and enhancing ownership transparency. The Government is staggering the implementation of ECCTA, and we have written about provisions that have come into force since ECCTA received Royal Assent in October 2023 in previous briefings here and here.

New dates to remember

We discussed the proposed identity verification (IDV) regime in our previous briefing here. The next step in the implementation timetable is to bring into force these much-anticipated provisions around verifying the identity of directors (and equivalents for other entities) and persons with significant control (PSCs). At the end of last month, the Registrar (Identity Verification and Authorised Corporate Service Provider) Regulations 2025 (the Regulations) were published setting out the framework for IDV and how to register as an Authorised Corporate Service Provider (ACSP). Earlier this month, Companies House published three sets of Registrar’s rules for IDV and registering as an ACSP (the Rules, detailed below), which set out the information and acceptable types of evidence that applicants will be required to submit when applying to verify their identity. 

More dates for implementation have also been released. It was previously announced that ACSP registration would open on 25 February 2025 and voluntary IDV would be available from 25 March 2025. At the time of writing, Companies House is still targeting 25 March 2025 to launch voluntary IDV but it has delayed ACSP registration, which will now open in “Spring 2025”. We are still waiting for confirmation of the exact dates for the introduction of compulsory IDV on new incorporations and the start of the transition period for existing directors and PSCs to complete IDV (most recent commentary suggests this will be from Autumn 2025). By Spring 2026, presenters filing documents at Companies House will also be required to IDV. This staggered approach is necessary due to operational constraints at Companies House. 

The new Rules

As discussed in our previous briefings, there will be two routes for IDV: (i) digitally via Companies House; or (ii) via an ACSP delivering a verification statement to Companies House. The Rules confirm that all applicants will need to have a suitable email address and be a registered user of Companies House services. They must also be available to answer any additional questions to support their IDV application.  

Set out below is a brief explanation of each of the Rules that create the practical framework around IDV.

• The Registrar’s (Identity Verification by the Registrar) Rules 2025

These rules detail how applicants can complete IDV directly via the Companies House portal together with what evidence will need to be submitted with the application. There will be three options to complete Companies House IDV: (i) a “selfie” option via a smartphone; (ii) a series of security questions online via the GOV.UK login web service; or (iii) a combination of submitting evidence via the online portal and physical document checks during a verification appointment at a local Post Office. These rules also set out the Registrar’s right to impose reverification obligations where appropriate.

• The Registrar’s (Identity Verification by Authorised Corporate Service Providers) Rules 2025

These rules define an ACSP’s approach to verify identities. They ensure a consistent and reliable approach to IDV across all ACSPs to match those IDV checks that will be completed if going directly to Companies House.

• The Registrar’s (Requirements Applicable to Applications to Become an Authorised Corporate Service Provider) Rules 2025

These rules specify the criteria and procedures for applying to become an ACSP. They aim to streamline the application process.

Once IDV is complete and approved, applicants will be given a “unique identifier” (ie a unique code) known as a UID. The UID can be used by that applicant to take on subsequent appointments without completing further verification steps as it will be linked to their existing Companies House account. That said, while there isn’t a regular renewal requirement, Companies House may ask an individual or corporate to complete a reverification exercise. This may be made with reason (such as someone changing their name) or without reason, and if such a request is made the Registrar can specify which route, method or evidence that must be used and can also ask additional questions of the individual or corporate.

Companies House guidance on the Rules

On 19 February 2025, Companies House published three sets of guidance notes (the Guidance) to help applicants meet the requirements of the Rules.

• Applying to register as a Companies House authorised agent

This sets out the eligibility criteria and the application process for anyone wishing to register as an ACSP in order to file information at Companies House and/or to provide IDV services. Once an application for registration is accepted, an authorised agent account for the applicant will be created.

• Being an Authorised Corporate Service Provider

This confirms the ACSP’s role and responsibilities and details how the ACSP can comply with its legal obligations. It also sets out how the ACSP can manage their authorised agent account at Companies House (for example update the agent’s details).

• How to meet Companies House identity verification standard

This details how an ACSP can meet its IDV obligations to the Companies House standard and discharge its legal responsibilities when completing IDV. ACSPs must keep records of evidence and information used to verify someone’s identity for seven years, irrespective of whether the ACSP completes the verification exercise for an applicant.

Comment

Confirming the intended dates to open voluntary IDV marks an important step in implementing some of the fundamental changes that will be brought into force by the provisions in ECCTA. We are starting to understand more about what IDV will look like in practice, and when it will be introduced and eventually become compulsory. The Regulations and the Rules are supported by the Guidance, which addresses the practical steps around what Companies House or an ACSP will need to do to check that the evidence submitted by an applicant is true. This is to ensure compliance with the IDV regime and to provide for ACSPs to meet Companies House’s IDV standard. We are waiting for commencement regulations which will bring into force the underlying provisions in ECCTA that create the IDV and ACSP frameworks.

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances. We will continue to monitor developments in this area. 

© Farrer & Co LLP, February 2025