ECCTA 2023 Identity Verification: What UK Directors Must Do (Nov 2025+)

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) is the most significant reform of the UK companies registration regime in decades. Among its provisions, mandatory identity verification (IDV) for directors, Persons with Significant Control (PSCs), and presenters has begun phased implementation through 2025–2026. This update explains what the law requires, the current rollout status, and what every UK director must now do.

The Law in One Sentence

Under the Economic Crime and Corporate Transparency Act 2023, every individual director of a UK company, every PSC, every member of an LLP, and every person filing on behalf of a company must verify their identity through GOV.UK One Login or via an Authorised Corporate Service Provider (ACSP).

Statute: https://www.legislation.gov.uk/ukpga/2023/56/contents.

Government implementation hub: https://changestoukcompanylaw.campaign.gov.uk/.

Who Must Verify

Two Routes to Verify

Route 1 — Direct Verification via GOV.UK One Login

The standard, no-fee route. Steps:

1. Sign in (or create) a GOV.UK One Login account at https://www.gov.uk/sign-in
2. Choose “Verify your identity for Companies House”
3. Provide a verification document:
   • UK passport
   • Non-UK passport (verification possible from overseas)
   • UK driving licence (photocard)
   • Biometric residence permit (where still in circulation)
4. Complete a facial-match check via the GOV.UK ID Check app
5. Receive verification reference (the Personal Code)
6. Use the Personal Code in the next IN01 / AP01 / PSC01 filing

The verification covers all future Companies House interactions for that individual.

Route 2 — Verification via an Authorised Corporate Service Provider (ACSP)

Where the digital flow fails (e.g. facial-match technology issues with non-UK documents) or where the individual prefers in-person verification, an ACSP can verify. ACSPs are regulated entities (typically law firms, accountants, formation agents) authorised under ECCTA 2023.

Important: MmowW Scrib🐮 is not an ACSP. Scrib🐮 is a document preparation service. Where ACSP-route verification is needed, the user engages a separate authorised provider.

ACSP guidance: https://www.gov.uk/guidance/identity-verification-at-companies-house.

Phased Rollout Timeline

The ECCTA 2023 identity verification regime has rolled out in stages:

The exact dates of Phase 3 and Phase 4 are set by commencement regulations under section 219 of the ECCTA 2023. See the live timetable at the changes-to-uk-company-law campaign site: https://changestoukcompanylaw.campaign.gov.uk/.

Consequences of Non-Verification

Acting as a director without verification (after the relevant phase commencement) is a criminal offence under ECCTA 2023, punishable on summary conviction by a fine. Specific consequences:

• Filings rejected. Companies House will reject IN01, AP01, PSC01, etc. submitted by an unverified person.
• Confirmation statement query. Existing companies may receive ECCTA queries on confirmation statements where directors or PSCs remain unverified.
• Strike-off risk. Where a company cannot complete its annual confirmation statement because one or more officers are unverified, strike-off proceedings may follow.
• Personal criminal liability. Acting as a director after the deadline without verification.
• Loss of statutory excuse for non-compliance. Companies cannot rely on “we tried to file” if their officers are unverified.

What Directors Must Do Now

For New Companies (Forming after November 2025)

All directors and PSCs verify before the IN01 is filed. Without verification, the IN01 will be rejected.

For Existing Companies (Incorporated Before November 2025)

All directors and PSCs must verify ahead of the next confirmation statement filing (Phase 3 in 2026). Practical recommendation: verify now. The process is free, takes 5–10 minutes for most people, and removes a future blocker.

For Non-Resident Directors

Non-resident directors complete verification through GOV.UK One Login from overseas using their passport. The facial-match flow works internationally. Where it fails, an ACSP-route is the alternative.

For Existing Officers Who Have Resigned

Resigned directors do not need to verify retrospectively. Verification applies to ongoing or future-appointed officers.

Practical Checklist

For each director and PSC of every UK company:

• Have they completed GOV.UK One Login identity verification?
• If yes, is the Personal Code recorded in the company’s officer records?
• If no, schedule verification within the next 30 days
• If facial-match flow fails, identify an ACSP for backup verification
• Update the company’s compliance calendar to record verification status

Common Mistakes — Gyoseishoshi View

1. Assuming the company secretary verifies on behalf of directors. No. Each individual must verify themselves. Verification is personal, not corporate.

2. Believing only “active” directors need to verify. No. Every director on the register, including those who never attend meetings, must verify.

3. Treating verification as optional after Phase 2. Phase 2 (November 2025) made verification mandatory for new appointments. Existing officers continue to need verification for Phase 3 alignment.

4. Using a passport that has just expired. The verification document must be valid. Renew the passport first.

5. Assuming an ACSP can verify all directors of a company in one batch. ACSPs verify each individual separately. Each director is verified once and the verification is portable across companies.

6. Mistaking the GOV.UK One Login account for the verification. Creating an account is the first step; the verification (facial match + document) is a further step.

7. Filing under another person’s verified status. This is identity fraud. Do not “share” Personal Codes.

How ECCTA Connects to Other Reforms

The identity verification regime sits alongside other ECCTA changes already in force:

• Registered office reform (March 2024). PO Boxes prohibited; registered office must be an “appropriate address” under the amended s.86.
• Registered email address requirement (March 2024). Every company must hold a registered email address under the new s.88A.
• Lawful purpose statement. Every IN01 must include a statement that the company is being formed for lawful purposes (s.9(2)(d) as amended).
• Companies House query, reject, and remove powers. Active gatekeeping replaces passive recording.
• Companies House fee increases (1 February 2026). Funding the new compliance regime — see https://www.gov.uk/government/news/companies-house-fees-are-changing-from-1-february-2026.

What This Means for Founders Today

Three actions:

1. Verify yourself today if you are a director or PSC of a UK company. The process is free and quick.
2. Verify your co-directors and PSCs. Send each of them the verification link. Track completion.
3. Update your compliance calendar. Verification status should be a tracked item alongside accounts and confirmation statements.

Conclusion

ECCTA 2023 identity verification is no longer optional. New appointments since November 2025 already require it; existing officers must verify through 2026. The process is free, takes minutes, and removes a future filing blocker. Verify proactively rather than reactively — the alternative is a stalled filing at exactly the wrong moment.

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Disclaimer

This article provides legal information, not legal advice. MmowW Scrib🐮 is a document preparation service operated by a licensed Gyoseishoshi (行政書士) office in Japan. We are not solicitors, barristers, or attorneys.

Sources

1. Economic Crime and Corporate Transparency Act 2023: https://www.legislation.gov.uk/ukpga/2023/56/contents
2. Identity verification at Companies House: https://www.gov.uk/guidance/identity-verification-at-companies-house
3. Changes to UK company law (campaign hub): https://changestoukcompanylaw.campaign.gov.uk/
4. GOV.UK Sign In: https://www.gov.uk/sign-in
5. Companies House fees from 1 February 2026: https://www.gov.uk/government/news/companies-house-fees-are-changing-from-1-february-2026