Important Companies House changes identity verification and who can file for changes

Companies House is introducing a new requirement for directors, people with significant control and members of LLPs to verify their identity with Companies House and changes to how documents/information are filed at Companies House.

Identity Verification (IDV)

From 18 November 2025, the following people MUST verify their identities with Companies House:

• all (new and existing) directors, people with significant control and members of LLPs (unless exempt, e.g. for national security reasons). 

• any individual who is filing on behalf of a company (e.g. an employee).

Identity can be verified voluntarily from April 2025.

IDV will be important once it becomes mandatory since a director who has not verified their identity must not act in their capacity as director or a member of an LLP who has not verified must not act in their capacity as a member until they have completed IDV.

If a director, PSC or LLP member does not complete IDV when required, other consequences may include:

• criminal proceedings with the potential of an unlimited fine;

• civil penalties imposed by the Registrar of Companies;

• applications to register/incorporate being rejected by the Registrar;

• being unable to make statutory filings;

• marking an individual’s status as “unverified” on the public register; and

• the likelihood that banks will not lend to “unverified” persons.

There are various ways in a person can verify their identity:

• using the GOV.UK app, which involves the submission of a photo of an approved form of photo ID (e.g. a passport) and a selfie via a smartphone (of the director(s) in the case of a company);

• using the GOV.UK login web service, which involves answering a series of security questions online;

• at a post office, provided that a face-to-face verification appointment has been booked via the GOV.UK website;

• via an “authorised corporate service provider” (ACSP) (i.e. solicitors or accountants who register as ACSPs with Companies House. 

Once IDV is completed, the person will be issued with a “unique identifier” (i.e. a number unique to them) which has to be quoted on all future filings at Companies House.

Hill Dickinson does not currently intend to offer an IDV service and any identification process carried out for Hill Dickinson is not equivalent to completing IDV as the IDV process is a separate, governmental requirement.

However, the government has indicated that the apps and web service mentioned above are user friendly and there are firms offering IDV services if you wish to use an intermediary.

Changes to filing documents/information at Companies House

With effect from Spring 2026, in order to cut down on fraudulent filing, Companies House is limiting which people can file documents/information: 

• an individual can file documents to Companies House on their own behalf, if they have completed IDV (unless they are exempt)

• an employee or officer of a firm/company can file documents on behalf of that firm/company if they have completed IDV (unless they are exempt)

• an ACSP can file documents on behalf of that firm/company 

Third parties (e.g. solicitors or accountants) who file documents for individuals or firms/companies can do so until Spring 2026 and can continue to do so after that if they register as an ACSP.

Hill Dickinson LLP intends to become an ACSP and so will be in a position to file before and after the Spring 2026 deadline.

What to do now?

To avoid the rush and the inevitable delays as the deadlines approach, individuals and companies should:

• consider who will need to complete IDV and gather the documents that will be required;

• check whether there are any corporate directors in the group (as they will need to provide additional information);

• take advantage of the opportunity to verify voluntarily now as Companies House will be under huge pressure once the IDV requirement becomes mandatory on 18 November 2025;

• make a record of the “unique identifier” number which is issued to the relevant director, PSC or LLP member once IDV is completed as it will be needed for future filings/correspondence with Companies House;

• consider who within their organisation needs to complete IDV in order to file documents at Companies House after Spring 2026.

If you need help, then do please get in touch and we can talk you through the processes.