18 November 2025 was not a single identity-verification deadline for every director and person with significant control in the United Kingdom.
It was the start of mandatory implementation and a 12-month transition.
The practical question in 2026 is not simply “have you verified?” It is “what role do you hold, when did that role begin, when must your verified identity be linked to that role, and through which filing or service?”
That distinction matters because a person can verify identity once and still have separate steps to connect that verification to each relevant company role.
Three key takeaways
- 18 November 2025 was a start date, not one universal deadline. Existing directors and PSCs entered a transition with timing linked to their roles and company events.
- Verification and role linkage are separate steps. A person receives a Companies House personal code after verification and uses that code where required to connect the verified identity to company appointments or PSC records.
- Director and PSC obligations are not identical. A person who is both can have separate actions and timing for each capacity.
What changed on 18 November 2025
Companies House states that identity verification became a legal requirement from 18 November 2025 and explicitly says that this date was not a deadline. It marked the start of a 12-month transition period.
The implementation distinguishes between new and existing roles.
For a new director, the personal code is used as part of the appointment or incorporation process.
For an existing director, Companies House guidance says the personal code must be provided as part of the company’s next confirmation statement during the transition.
PSCs operate through a different timing mechanism. Companies House says each PSC has a 14-day period in which to provide the personal code and verification statement, with the relevant dates depending on when the PSC was registered and, for existing PSCs, whether the person is also a director.
The rules therefore cannot be reduced to one calendar date copied across every company.
Verification is personal
After identity verification, Companies House issues an 11-character personal code.
The code belongs to the individual, not to a particular company.
A director of several companies does not verify from zero for each company. The same personal code is used to confirm that the person’s identity has been verified for the relevant appointments.
That is operationally useful.
But it creates a second concept that should remain separate:
identity verification establishes the person’s verified identity;
role linkage connects that verified identity to the director, PSC or other relevant role in the register.
A person can therefore truthfully say “I have verified my identity” and still have company-specific actions outstanding.
Directors: the next confirmation statement matters
For an existing director, the transition is closely tied to the company’s confirmation statement.
Companies House guidance says the director provides the personal code as part of the company’s next confirmation statement.
If the same person is a director of more than one company, the verified identity must be linked appropriately to each appointment.
This means a multi-company founder should not manage identity verification as one personal task with one tick box.
The better view is:
one verified person → one personal code → multiple company-role linkages
PSCs: a different timetable
PSCs need separate attention.
Companies House provides a specific service for supplying PSC verification details and states that each PSC has a 14-day period in which to provide the personal code and verification statement.
The relevant period depends on the person’s circumstances.
For example, the rules distinguish PSCs registered before 18 November 2025 from those added afterwards, and distinguish existing PSCs who are also directors from those who are not.
This is why a director-and-PSC should not assume that the confirmation statement automatically resolves every PSC step.
The same individual can have two legal capacities.
Verification routes
Companies House allows individuals to verify their identity directly through GOV.UK One Login where the service requirements can be met.
An Authorised Corporate Service Provider can also verify identity within the applicable framework.
The route chosen affects how the verification is performed, not the underlying need to use the resulting verified identity correctly in the register.
For an international director or PSC, this should be treated as a corporate-maintenance task, not merely a one-off personal KYC exercise.
A practical scenario
Consider a founder who is both director and PSC of a UK private company and who lives outside the UK.
The founder verifies identity and receives a personal code.
That does not mean every step is automatically complete.
The company should still determine:
- when its next confirmation statement falls;
- when the director’s verified identity must be linked through that process;
- the PSC’s specific 14-day period;
- whether the director and PSC linkages have both been completed; and
- whether the same person holds roles in other companies requiring their own linkage.
The important operational object is not just the code.
It is a role-by-role compliance map.
The strongest objection: most people verify only once
That is also correct.
Companies House designed the personal code so that individuals normally do not repeat the identity-verification process for each company. The same code can be reused to confirm verification across appointments.
That makes the system simpler than performing a fresh identity check for every role.
But “verify once” should not be confused with “take one action once.”
The identity is personal; the legal roles are multiple.
The transition year is largely about connecting the two.
What remains separate
Identity verification should not be confused with other UK or international compliance concepts.
It is not the same as:
- determining whether someone is a PSC;
- a bank’s customer-due-diligence process;
- beneficial-ownership analysis in another jurisdiction;
- filing the confirmation statement itself; or
- the tax residence of the director or company.
A founder with an international structure may therefore have several simultaneous layers:
person → residence → UK company → director/PSC status → Companies House verification → bank KYC → tax and corporate maintenance
Completing one layer does not complete the others.
The practical checklist
For every natural person connected to a UK company, record:
Role. Director, PSC, both, or another category.
Status. New or existing at the relevant implementation date.
Verification route. Companies House directly or an ACSP.
Personal code. Received and stored securely.
Company linkage. Which appointments have been connected to the verified identity?
Deadline mechanism. Confirmation statement, PSC 14-day window or another role-specific rule.
Evidence. Confirmation that the required filing or verification statement has actually been submitted.
This is a small compliance system.
It is also a good example of the direction of modern corporate registers: knowing that a company exists is no longer enough. Registers increasingly want a stronger link between the legal entity and the real people running or controlling it.
Sources
- Companies House — Verify your identity for Companies House
- Companies House — When you need to verify your identity
- Companies House — Personal codes for identity verification
- Companies House — Provide identity verification details for a PSC
- Companies House — Identity verification rollout from 18 November 2025
Disclaimer
This article provides general information only and does not constitute UK legal, company-secretarial or tax advice. Companies House implementation is continuing and timing depends on the person’s role and company circumstances. Current Companies House guidance should be checked immediately before any filing or verification action.
