Companies House’s move to introduce mandatory identity verification (IDV) on 18 November 2025 marks a major shift in the UK’s approach to corporate oversight.
For many years, the register prioritised speed and accessibility, relying heavily on self-reported information that could be vulnerable to misuse. The increasing use of fictitious or stolen identities exposed structural weaknesses in the system and underscored the need for a more robust, verified register.
For solicitors and their clients, the new IDV regime represents a fundamental change. Companies House is no longer simply collecting information but acting as an active gatekeeper, raising the assurance level required during incorporations, director appointments and wider governance processes. The aim is clear: to strengthen the integrity of the register by ensuring only genuine individuals can form or control companies. It reduces opportunities for fraud, money laundering and other forms of economic crime.
Law Society guidance
To support the profession through this shift, members of the Law Society’s Company Law Committee have produced comprehensive guidance. This resource helps practitioners understand IDV requirements and comply with the Economic Crime and Corporate Transparency Act 2023. The committee has worked closely with the Department for Business and Trade and Companies House throughout the development of the Act to ensure the views of company lawyers and their clients are reflected.
The guidance is particularly relevant for those who routinely file documents at Companies House such as incorporations, people with significant control (PCS) updates, LLP registrations, changes in directors and IDV confirmations.
The guidance explains what solicitors must consider when confirming that an individual’s identity has been verified:
- Potential liability under section 1112 of the Companies Act 2006 if a confirmation is later found to be misleading or false.
- A structured, practical approach to checking personal codes, confirming names and reviewing evidence or Companies House annotations.
Recognising the limitations of the current system, such as the inability to independently cross-check personal codes when documentation is missing, names do not match, or reverification is required, encourages proportionate judgement to scrutinise further. By offering clarity on expectations, examples of reasonable steps and guidance on navigating uncertainties, the guide helps reduce common pain points for solicitors. It supports more consistent and compliant filings, helps avoid unnecessary requisitions and gives practitioners greater confidence when dealing with IDV obligations on behalf of clients.
What’s next
Identity Verification is being phased in gradually. While mandatory verification now applies to new and existing directors and PSCs, there is a transitional period available to current office holders. In 2026, the regime is expected to expand to additional roles, including those linked to limited partnerships, corporate officers of PSCs and individuals who file on behalf of companies. Once the transitional period expires, Companies House will move to active enforcement, with non-compliant filings potentially being rejected and penalties applied.
As the regime continues to evolve, operational developments and clarifications will follow. The Law Society will keep this guidance under review and update it to ensure members remain supported as new requirements come into force.
Lucy Reeve is chair of the Law Society’s Company Law Committee and partner at Linklaters LLP
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