Companies House Identity Verification: An Update

As at 23 September 2026 approximately 68% of directorships had verified IDs – but 1,817,822 directorship IDs were overdue. The position in relation to PSCs was worse, only 56% were verified and 1,837,060 verifications were overdue. Yet we are 85% through the year to 18 November 2026.

Many company directors who have now completed the Companies House identity verification process and have received their Companies House personal code may assume that their obligations under the Economic Crime and Corporate Transparency Act reforms have been satisfied.

Unfortunately, for some individuals that assumption may be wrong.

A growing compliance issue concerns persons with significant control (PSCs) who have successfully verified their identity but have not completed the separate step needed to connect that verified identity to every role they hold on the Companies House register. 

One person, multiple roles

In many owner-managed businesses, the same individual appears on the Companies House register in more than one capacity.

For example, a business owner may be:

• A director of the company, and
• A person with significant control (PSC).

The key point is that identity verification relates to the individual, but compliance obligations relate to each registrable role.

An individual may therefore have successfully completed identity verification, received a Companies House personal code and have been recorded on a company’s Confirmation Statement as having a verified ID, yet still have an outstanding requirement relating to their PSC status. Industry commentary has highlighted this distinction and identified it as a common source of misunderstanding. 

The trap for accountants and compliance professionals

Many accountants have concentrated on ensuring that clients who are directors complete their identity verification and file a Confirmation Statement before the relevant deadlines.

That is understandable. Directors are usually the individuals with whom the accountant has the closest contact, and director verification requirements have received considerable attention.

However, PSC obligations follow a separate process and timetable. Companies House confirms that PSCs will be chased for outstanding ID verification – even where the same individual has already been verified as a director. 

The danger is that an adviser assumes everything is complete, when in fact the PSC requirement has not yet been satisfied.

Why this matters

The consequences are potentially significant.

A PSC who fails to provide the required verification details can find themselves subject to enforcement action. Companies House states that non-compliance with identity verification requirements may constitute an offence and can lead to penalties or fines. 

In addition, a public indication of non-compliance may appear against the individual's name on the register. 

For accountants, there is also a reputational risk. A client may understandably question why they were advised to complete identity verification but were not warned about the additional PSC-related step.

Practical steps to take now

A sensible review would include the following:

1. Identify all individuals who are PSCs of client companies.
2. Determine whether each PSC has completed identity verification.
3. Confirm that the PSC has received a Companies House personal code.
4. Check that the personal code has been properly associated with the PSC role, not merely with any directorship.

Where an individual holds multiple Companies House roles, do not assume that completion of one process automatically satisfies all obligations.

Conclusion

The question accountants should be asking is not simply:

"Has this individual verified their identity?"

The more important question is:

"Has the verified identity been correctly linked to every Companies House role that individual holds?"

For many PSCs, the distinction will make no difference because the necessary filings have already been completed. For others, however, it may be the difference between compliance and an enforcement letter from Companies House.

As the identity verification rollout approaches completion, now is an appropriate time for firms to review their PSC population and ensure that no client has fallen into this surprisingly common compliance trap - and you might want to start by checking the PSC register for your own firm!