From 18 November 2025 there have been important changes introduced by UK Companies House. This blog summarises the key features of the most important changes.
Confirmation Statements
On the first occasion that a company files a Confirmation Statement, on or after 18 November 2025, it will be necessary, as part of the filing process, to quote an 11-character personal ID verification code for every director of the company. These 11-character personal ID verification codes have been being issued by Companies House since April 2025 to individuals who have a verified ID (either using GOV.UK One Login or via an Authorised Corporate Service Provider) and apply for a personal code.
The 11-character personal ID verification code for an existing company director cannot be submitted earlier than on the occasion of the submission of the company’s first Confirmation Statement filed on or after 18 November 2025.
The submission of a Confirmation Statement is required by each company annually.
A Confirmation Statement normally has a ‘made up date’ (the date to which the relevant information is required to be updated) one year after ‘made up date’ of the immediately preceding Confirmation Statement or, where there has been no previous Confirmation Statement, one year after the date of the company’s incorporation.
However it is open to a company to supply a Confirmation Statement (with an earlier ‘made up date’) at any time.
A Confirmation Statement is due to be filed at Companies House within fourteen days after the ‘made up date’ and cannot be filed before its ‘made up date’.
Persons of Significant Control
Each individual who is a Person of Significant Control (PSC) of a company is to be required to quote their 11-character personal ID verification code to Companies House. The timing of that requirement will depend upon whether the Companies House system recognises the individual as a person who is also a director of the company.
Where the individual is recognised as a person who is both a director and a PSC of the company, the code will be required to be submitted
- not earlier than one day after the first anniversary of the ‘made up date’ of the last Confirmation Statement which was filed, or was due to be filed, with a ‘made up date’ before 18 November 2025, and
- not later than 14 days after the first anniversary of the ‘made up date’ of the last Confirmation Statement which was filed, or was due to be filed, with a ‘made up date’ before 18 November 2025.
Where the individual is not recognised as a person who is both a director and a PSC of the company, the code will be required to be submitted
- not earlier than the first day of the month in which their birthday next falls after 30 November 2025, and
- not later than the fourteenth day of that month.
It is not possible to file a PSC’s 11-character personal ID verification code earlier than the dates set out above. It is however possible to file the PSC’s personal ID verification code late (with the risk of a financial penalty for a late submission).
The effect of these requirements
The effect of these requirements is that over a period of approximately 12 months from 18 November 2025 an 11-character personal ID verification code for every company directorship and every PSC holder will be required to be submitted to Companies House.
However, from the perspective of the individual who is a company director and/or a PSC, if they hold more than one position (such as being both a director and a PSC of the same company, or being a director and/or PSC of more than one company) that individual may be required to file their 11-character personal ID verification code at Companies House on more than one occasion and on different dates.
Companies House expects over eight million personal code submissions to be required from company directors and over six million personal code submissions to be required from PSCs.
Checking the date on which each submission is required
It is possible to check the date on which each submission is required (or whether it has already been completed) by searching the Companies House website and checking on the company’s record the entry there for the appropriate director or PSC.
New appointments
Where an individual is appointed a director, or becomes a PSC, of an existing company on or after 18 November 2025 then slightly different rules apply.
A newly appointed director is required to submit their 11-character personal ID verification code as part of the process of submitting details of their appointment to Companies House.
An individual becoming a PSC is required to submit their 11-character personal ID verification code to Companies House within 14 days of being added to the company’s PSC Register.
Newly incorporated companies
Where an application is made to incorporate a new company the 11-character personal ID verification code for each proposed director of the new company must be supplied before the incorporation can proceed.
The 11-character personal ID verification code for each PSC can be supplied on incorporation or within the next 14 days.
Tips
In most cases the most efficient way to deal with these requirements, when first submitting a Confirmation Statement for any company on or after 18 November 2025, will be to delay submitting the Confirmation Statement until at least one day AFTER the ‘made up date’. It should then be possible, on the same day, to submit the 11-character personal ID verification code TWICE for each individual who is both a director and a PSC of the same company.
If you use company secretarial or AML compliance software that should assist you to (i) retain the 11-character personal ID verification codes for directors and PSCs of client companies, and (ii) submit those codes to Companies House on the dates on which those codes are required.
