From 18 November 2025, Companies House fully introduced its new identity verification regime for company directors and persons with significant control (PSCs). While the policy objective is to improve transparency and reduce fraud, the practical reality has been far more complex.
As David Winch explained in his webinar “Companies House – Changes Made & Next Steps”, the early months of implementation have revealed systemic problems, low compliance rates, and significant administrative burdens for companies and advisers alike.
This article focuses on two key questions:
- What problems are being encountered in practice?
- What should companies and advisers do now to reduce risk and disruption?
Problems Found in Practice
1. The Two-Stage Process Is Widely Misunderstood
One of the most common problems is a fundamental misunderstanding of how the new system works.
The process has two distinct stages:
- An individual obtains their 11-character Companies House personal ID code after verifying their identity.
- That code must then be linked to each directorship and each PSC role, during a specific Companies House “submission window”.
Many directors believe that once they have obtained the ID code, they are “done”. In reality, nothing is compliant until the code is successfully submitted and accepted against each role on the register.
2. Submission Windows Are Fragmented and Hard to Track
Submission windows are:
- Different for each company
- Different for directorships and PSCs
- Often different even where the same individual is both director and PSC
For advisers managing dozens or hundreds of companies, this creates a logistical nightmare. The Companies House system will not allow early submission, even if all information is ready. Missed windows result in overdue statuses and warning letters.
3. Extremely Low Compliance Rates
Early data shows alarming uptake levels:
- Only around 7% of pre-existing directors
- Only around 3% of pre-existing PSCs
have successfully completed the process so far. Hundreds of thousands of directorships and PSC positions are already flagged as overdue, with numbers rising daily.
Companies House has begun issuing warning letters, and civil penalties are expected to follow.
4. Name Mismatch Errors Are Widespread
The most common technical failure is the “name mismatch” problem.
Identity verification is typically completed using a passport or driving licence, which often shows a person’s full legal name (e.g. William George Jones). However, Companies House records may show a shortened or preferred name (e.g. Bill Jones).
When the ID code is linked, Companies House checks for an exact match — and rejects many submissions.
While Companies House allows “preferred name” explanations, many users are unaware of this option, causing avoidable delays.
5. Directors Who Are Also PSCs Are Being Missed
A surprisingly frequent error is submitting the code only once.
If an individual is both:
- a director, and
- a PSC
the code must be submitted twice, once for each role. The system does not assume they are the same person unless records align perfectly. Failure to submit both leads to overdue PSC filings, even where the director record is compliant.
Dates of Birth Block Submissions
Where historic Companies House records contain an incorrect date of birth, ID codes will not be accepted. Correcting these errors can require:
- Paper filings
- Multiple forms
- Long delays
Some advisers are using pragmatic workarounds (such as ceasing and re-appointing roles), but these leave questionable audit trails and are not officially endorsed.
What Should You Do Now?
Despite the frustrations, there are practical steps companies and advisers should take immediately.
1. Encourage Early ID Verification
Even if a submission window has not yet opened, directors and PSCs should verify their ID as soon as possible. This flushes out:
- Name mismatches
- ID problems
- Missing documents
early, rather than discovering them when deadlines are looming.
2. Audit Companies House Records Now
Review each client company for:
- Inconsistent naming between director and PSC records
- Incorrect dates of birth
- Duplicate or outdated PSC entries
Fixing these issues before submission windows open will save significant time and risk later.
3. Track Submission Windows Systematically
Manual tracking is risky. Consider:
- Specialist company secretarial software
- Centralised tracking spreadsheets (with clear ownership)
- Dedicated responsibility within the firm
Failing to track windows accurately is now a compliance risk, not just an inconvenience.
4. Delay Confirmation Statements Strategically
Where possible, do not file confirmation statements on the exact made-up date. Waiting at least one day can allow both director and PSC codes to be submitted together, reducing repeat work and errors.
5. Consider Voluntary Strike-Offs
For dormant or unused companies, voluntary strike-off may now be the sensible option — especially with the fee reducing from £33 to £13 from February 2026. This avoids ongoing compliance obligations entirely.
6. Prepare for the Next Phase (Spring 2026)
From spring 2026, anyone filing documents at Companies House (not just directors and PSCs) will need verified authority — either as:
- A company officer with verified ID, or
- An employee of an Authorised Corporate Service Provider (ACSP)
Most accountancy firms will need to become ACSPs to continue filing for clients.
The Companies House ID verification regime is not a minor procedural change. It represents a fundamental shift in responsibility, timing, and risk for companies and their advisers.
The system is imperfect, compliance levels are low, and enforcement is only just beginning. Firms that act early — by cleaning data, educating clients, and upgrading systems — will be far better placed than those who wait for penalty notices to arrive.
As David Winch made clear, this is not going away. The question is not whether you engage with it, but how prepared you are when Companies House starts enforcing it in earnest.
Frequently Asked Questions (FAQ)
What changed on 18 November 2025?
From 18 November 2025, Companies House fully implemented mandatory ID verification for all company directors and Persons with Significant Control (PSCs). Existing directors and PSCs have a 12-month transitional period to comply, using Companies House–allocated submission windows.
Is this a one-off requirement?
No. ID verification is the start of a wider reform programme. Further changes are expected from spring 2026, extending verification requirements to people who file documents at Companies House.
What is a personal ID code?
A personal ID code is an 11-character unique identifier issued by Companies House to an individual after their identity has been verified. The code belongs to the person, not the company.
Do directors and PSCs need more than one personal ID code?
No. Each individual only needs one personal ID code, regardless of how many companies they are involved with.
However, that same code must be submitted separately for each directorship and each PSC role.
Does obtaining the personal ID code make someone compliant?
No. Obtaining the code is only stage one.
Compliance only occurs when the code is successfully submitted and accepted against each role (director and/or PSC) during the correct submission window.
What is a submission window?
A submission window is a limited period during which Companies House allows a personal ID code to be linked to a specific directorship or PSC role. The system will not accept early submissions.
Are submission windows the same for directors and PSCs?
No. Submission windows:
- Differ between directors and PSCs
- May differ even where the same individual is both director and PSC
- Are typically based on company incorporation dates or, for PSC-only roles, the person’s birth month.
What happens if the window is missed?
The code can still be submitted after the deadline, but the role will be marked overdue, and Companies House has begun issuing warning letters. Civil penalties may follow.
How can I find a submission window?
Submission windows are visible on the Companies House company record, under the People tab, for each director and PSC individually.
Why am I getting a “name mismatch” error?
This happens when the name used during ID verification (usually from a passport or driving licence) does not exactly match the name recorded at Companies House.
Examples include:
- Bill vs William
- Missing middle names
- Slight spelling differences
How do I fix a name mismatch?
You have two main options:
- Select the “preferred name” explanation when prompted
- Amend the Companies House record to match the verified name
Both approaches are acceptable, depending on circumstances.
Why does the system think a director and PSC are different people?
If names, dates of birth, or formatting differ between director and PSC records, the system may fail to recognise them as the same individual. This can cause:
- Separate submission windows
- Unexpected birthday-based PSC deadlines.
What if the date of birth on Companies House is wrong?
If the Companies House date of birth differs from the verified ID:
- The ID code will be rejected
- The record must be corrected (often via paper filings)
Some advisers are using cease-and-reappoint workarounds, but these are not formally endorsed.
Do director-PSCs need to submit their code twice?
Yes. If someone is both:
- a director, and
- a PSC
the personal ID code must be submitted once for the directorship and once for the PSC role. Submitting it only once leaves the other role non-compliant.
Why does one role show as compliant but not the other?
Because Companies House treats director and PSC records as separate filings, even where they relate to the same person.
Can I submit ID codes via the confirmation statement?
Yes, but timing matters.
If the confirmation statement is filed too early, PSC windows may not yet be open, requiring a second filing later.
Is there a best practice for confirmation statements?
Yes. Where possible:
- Wait at least one day after the made-up date
- Submit director and PSC codes together
This reduces duplication and follow-up work
What if a director or PSC has no email address?
An email address is mandatory. Options include:
- Setting up a new email address solely for this purpose
- Using a trusted person’s email (with care and consent)
What if someone has no passport or photo ID?
Alternative routes include:
- Post Office identity verification
- Financial-history based checks
However, some individuals (elderly, incapacitated, imprisoned) may face significant difficulties, and there is currently no easy solution
Can overseas directors verify their ID?
Yes. Most non-UK passports with biometric chips can be used successfully via the online verification process
What penalties apply for non-compliance?
Companies House now has enhanced civil penalty powers. Initial enforcement has focused on warning letters, but fines are expected to follow as the regime matures
Are accountants responsible if filings are late?
Legally, the obligation sits with the company and its officers.
Practically, clients often blame advisers — so tracking windows and submissions is now a professional risk issue
Looking Ahead – 2026 Changes
What is changing from spring 2026?
Anyone filing documents at Companies House will need authority as either:
- A verified company officer/employee, or
- An employee of an Authorised Corporate Service Provider (ACSP)
Will accountancy firms need to become ACSPs?
In most cases, yes. Without ACSP status, firms will generally be unable to file accounts or other documents for clients
What should firms do now?
- Encourage early ID verification
- Audit Companies House records for inconsistencies
- Implement systems to track submission windows
- Consider voluntary strike-off for dormant companies
- Prepare for ACSP registration if not already completed
The contents of this article are meant as a guide only and are not a substitute for professional advice. The author/s accept no responsibility for any action taken, or refrained from, as a result of the material contained in this document. Specific advice should be obtained before acting or refraining from acting, in connection with the matters dealt with in this article. The information at the time of publishing was accurate and could be subject to final changes.
