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Companies House Identity Verification: What UK Accountants Must Do

·Ali Amin

Companies House identity verification is no longer optional. Under the Economic Crime and Corporate Transparency Act 2023, all individuals who file with Companies House — directors, persons with significant control (PSCs), and those who file on behalf of companies — must verify their identity. For existing directors and PSCs, the deadline to complete verification is 18 November 2026. After that date, operating as a director without verified identity is a criminal offence.

For accounting practices, this creates two separate obligations: verifying the identity of anyone at the firm who files with Companies House on behalf of clients, and helping client directors and PSCs understand and meet their own verification deadline. Neither obligation is optional, and both are time-sensitive given how many client companies a typical practice acts for.

This guide covers what identity verification involves, who it applies to, what the consequences of non-compliance are, and how practices can track and manage the deadline across their client base without building a separate manual system to do it.

What Companies House identity verification actually requires

Identity verification under the new regime works in one of two ways:

Direct verification is done through the Companies House online service. The individual provides a UK passport, driving licence, or national identity card, and Companies House verifies it digitally. This is the route for directors and PSCs who want to verify themselves independently.

Verification through an Authorised Corporate Service Provider (ACSP) allows an individual to verify their identity via a registered agent — an accountant, solicitor, or other business that has registered with Companies House as an ACSP. This is the route most relevant to accounting practices: the practice can verify client directors on their behalf as part of the firm's existing service relationship.

ACSP registration is separate from identity verification. If your practice plans to verify client directors and PSCs, the firm (or the relevant partners within it) must register as an ACSP first. Registration involves the firm itself verifying its identity and the identity of those who will conduct verifications on its behalf.

Who the deadline applies to

The 18 November 2026 deadline applies to:

  • All current directors of companies registered at Companies House
  • All current PSCs (persons with significant control) registered at Companies House
  • All LLP members
  • All individuals who act as corporate service providers and file with Companies House

It does not apply to shareholders who are not directors, employees of companies who are not directors, or individuals who simply own shares.

For a practice with 150 corporate clients, the typical exposure is 300–500 individuals who need to verify — multiple directors and PSCs per company, with some individuals appearing as director or PSC at more than one client company (meaning one verification covers multiple client relationships).

What happens if the deadline is missed

The consequences of non-verification after 18 November 2026 are material:

  • Operating as a director of a UK company without a verified identity is a criminal offence under the Economic Crime and Corporate Transparency Act 2023
  • Companies House can annotate the public register to show that a director or PSC has not verified their identity — a visible compliance flag
  • Companies House can impose restrictions on what the company can file until verification is completed
  • For practices acting as ACSPs, filing on behalf of a company with unverified directors creates regulatory risk for the firm

This is not an administrative penalty regime with a fine and a grace period — it is a criminal liability for the unverified individual. Practices should treat it with the same urgency they would apply to an HMRC filing deadline.

The practical challenge for accounting practices

The challenge for practices is not the verification process itself — it is tracking who among hundreds of client directors and PSCs has and has not verified, and ensuring that no client falls through.

For a practice acting for 100 companies, the tracking problem looks like this: each company has between one and ten directors and PSCs on the register; some individuals are directors of multiple clients; the verification status of each individual is not automatically reported to the practice — someone has to check or confirm it; clients are at different stages of awareness and urgency; and November 2026 is close enough that a disorganised chase process will miss people.

Manual tracking — a spreadsheet with one row per individual, updated as confirmations come in — is feasible for a small client base. For a practice with anything over 50 corporate clients, it becomes the same kind of coordination problem as HMRC deadline chasing: high-volume, repetitive, and high-consequence if mismanaged.

How automated tracking helps

An automated identity verification tracking workflow applies the same logic as deadline management for filings: identify who needs to act, trigger the communication at the right moment, log responses, and escalate non-respondents.

Step one: Build the tracking register. Export the list of directors and PSCs for each corporate client from your practice management system or from the Companies House API. Deduplicate individuals who appear at multiple clients. The register becomes the source of truth for who needs to verify.

Step two: Send the initial client communication. A sequenced outreach to each client company — explaining the requirement, the deadline, and the options (direct verification or via the practice as ACSP) — gives clients time to act without creating an urgent rush in October and November.

Step three: Track and chase. As verifications are completed, confirmation is logged against each individual in the register. Non-respondents receive a follow-up at defined intervals. The practice manager sees a dashboard showing verified / pending / uncontacted status across the full client list.

Step four: Flag stragglers before the deadline. From September 2026, any client with unverified directors should be flagged as high priority. The workflow escalates to a phone call rather than an email for clients approaching November 2026 without confirmation.

This is not a complex workflow. It is the same chase sequence that practices already run for annual accounts and confirmation statements, adapted to a one-time verification requirement with a hard statutory deadline.

ACSP registration — what practices need to do

If your practice plans to verify client directors on their behalf, ACSP registration is required before verifications can be conducted. The registration process involves:

  1. The firm applying through the Companies House service
  2. Verifying the identity of the practice's beneficial owners and certain key individuals within the firm
  3. Agreeing to the ACSP conduct standards

ACSP registration is not instantaneous — allow three to four weeks for processing. Practices that want to be ready to offer client director verification from the start of Q3 2026 should have registered by late July or early August at the latest.

The ACSP registration also has ongoing obligations: the practice must maintain accurate records of verifications conducted, must apply anti-money-laundering checks to the individuals it verifies, and must notify Companies House if the firm's registration details change.

Practices that do not register as an ACSP can still communicate the verification requirement to clients and direct them to verify directly through the Companies House service. They simply cannot conduct the verification on the client's behalf.

Connecting identity verification to ongoing deadline management

Identity verification is a one-time requirement — once verified, an individual's status is persistent and covers all their company directorships. But the Companies House deadline calendar continues after November 2026: confirmation statements, accounts filings, PSC register updates, and any future regulatory requirements the legislation introduces.

Practices that build verification tracking infrastructure now are building on the same foundation they need for ongoing Companies House deadline management. The client list, the director and PSC register, the communication sequences, and the escalation logic are all components of a broader filing deadline system.

The free Companies House Deadline Tracker available at Ihsan Ops handles the ongoing filing deadline calendar; the identity verification tracking layer can be built alongside it or integrated into the same system for practices that want a single view of all Companies House obligations per client.

Frequently asked questions

When is the Companies House identity verification deadline for existing directors?

18 November 2026. All existing directors, PSCs, and LLP members must verify their identity with Companies House by this date. After this date, operating without a verified identity is a criminal offence under the Economic Crime and Corporate Transparency Act 2023.

Do accountants need to verify their identity with Companies House?

Partners and staff who file with Companies House on behalf of clients must verify their identity if they are acting as individuals. Practices that register as Authorised Corporate Service Providers (ACSPs) can conduct verification on behalf of client directors and PSCs, but the practice itself must verify its beneficial owners and key individuals as part of the ACSP registration process.

What happens if a director misses the Companies House identity verification deadline?

Operating as a director of a UK company without verified identity after 18 November 2026 is a criminal offence. Companies House can also annotate the public register to flag non-verification and impose filing restrictions on the company. There is no standard fine-and-grace-period route — the liability is criminal.

How do accounting practices track Companies House identity verification for clients?

The most effective approach is an automated tracking register: a list of all directors and PSCs across the client base (deduplicated for individuals appearing at multiple clients), with a communication sequence that triggers the initial briefing, follows up on non-respondents at set intervals, and escalates to phone calls as November 2026 approaches. This is the same logic as filing deadline management, applied to a one-time verification requirement.

What is the Companies House ACSP registration and who needs it?

An Authorised Corporate Service Provider (ACSP) is a firm registered with Companies House to conduct identity verification on behalf of directors and PSCs. Accounting practices, solicitors, and other regulated businesses can register. ACSP registration is required if the practice wants to verify client directors on their behalf rather than directing them to self-verify. Allow three to four weeks for registration processing.

Tracking Companies House deadlines manually across a large client base? The Deadline Autopilot handles both ongoing filing deadlines and one-time compliance requirements as a fully managed service — book a 30-minute call to see what it covers.