ECCTA: Identity verification: Steps to take now to be prepared
18th February, 2025
A major change which is being introduced is the mandatory identity verification for all new and existing registered company directors, People with Significant Control and those delivering documents to the Registrar
Following on from our previous updates (available here and here) regarding changes under The Economic Crime and Corporate Transparency Act 2023 (the Act), Companies House recently published an update regarding the proposed implementation dates for further measures being introduced under the Act which aim to improve transparency and provide more accurate and trusted information on the registers.
Identity verification will also apply to all members of a limited liability partnership (LLP). There will be two ways to verify identity, either directly via the Registrar of Companies or through the use of an Authorised Corporate Service Provider. These verification checks will also be required when setting up a new company.
It will be a criminal offence for an individual to act as a director while their identity is unverified and the company will also commit a criminal offence if it allows a director to act while unverified.
Authorised Corporate Service Providers
From 25 February 2025, all third-party providers will need to register their business as an Authorised Corporate Service Provider (ACSP) before they can submit information and carry out identity verification checks on their clients. An ACSP is a business which is registered in the UK and subject to the UK’s anti-money laundering regime, which will include law firms and accountants.
Ward Hadaway intends to register as an ACSP and we will provide further details of the services we can provide to you and your business as soon as we are able. We currently await further details of the application process being published.
Identity verification
From 25 March 2025, Companies House expects that it should be able to allow individuals to voluntarily verify their identity via on online service.
By autumn 2025, it is expected that:
- identity verification will become a compulsory part of incorporation and new appointments for new directors and PSCs; and
- there will be a 12-month transition phase to require all existing directors and PSCs to verify their identity which will be required as part the annual confirmation statement filing.
By spring 2026, it is expected that:
- identity verification will be a compulsory part of filing any document;
- third party agents filing on behalf of companies will need to be registered as an ACSP; and
- Companies House will reject documents delivered by disqualified directors as they will be prohibited from doing so, unless they are delivered by an ACSP for specified filings permitted by law.
By the end of 2026, Companies House expects that all individuals on the register who are required to verify their identity will have done so compliance activity against those who have failed to verify their identity will begin.
We continue to monitor for further updates and the publication of secondary legislation and guidance. Please note the dates set out above are based on Company House publications and may be subject to change. As soon as we become aware of any further update we will let you know.
What can you do now and how can Ward Hadaway help?
To ensure your business is prepared, you should review your company information now. This is particularly important for large corporate groups, where information may be inaccurate.
This will include reviewing all director and PSC/RLE registers and ensuring that these and their details remain correct, both at Companies House and within the company’s statutory registers.
Getting this information corrected now will make it much simpler for companies to comply once the registration requirements come into effect.
Ward Hadaway can assist with reviewing and updating your information as required. Please contact us for further information on how we can help your business prepare for these changes.
Please note that this briefing is designed to be informative, not advisory and represents our understanding of English law and practice as at the date indicated. We would always recommend that you should seek specific guidance on any particular legal issue.
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