From 18 November 2025, a number of key company law changes introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA) will be in force, as previously signalled by Companies House. This includes:
- Identity verification (IDV) will be compulsory for all new directors, LLP members, or people with significant control (PSCs). Most existing directors, LLP members, and PSCs must complete their IDV before the date the company’s next confirmation statement is due. The exception is for existing PSCs who are not also directors of the company: they must submit their personal code (being the unique identifier given to each individual after completing IDV) to Companies House within the first 14 days of their birth month after 18 November 2025. For example, if the PSC’s date of birth is 22 December 1980, the deadline to submit their personal code is 14 December 2025.
- Directors of overseas companies with UK establishments registered at Companies House must also complete IDV. The deadline is the next anniversary of that entity’s registration at Companies House that falls after 18 November 2025. For example, if an overseas company was first registered at Companies House on 1 April 2013, its directors must complete IDV before 1 April 2026.
- The requirement for companies to maintain registers of directors, directors’ residential addresses, secretaries and PSCs will be abolished and replaced with a requirement to file specified information at Companies House.
- All companies will need to maintain their own register of members, as the option to elect to keep information that must be recorded in its register of members on the central register will be removed.
- The registrar of companies will have a new duty to annotate the register to indicate that an individual director, LLP member, or PSC has successfully verified their identity. This means it will be possible to check on Companies House to confirm that an individual has completed IDV.
How can IDV be completed? IDV can be done directly with Companies House either online via an app or using GOV.UK One Login, or in person at a Post Office. Alternatively, authorised corporate service providers (such as company secretarial vendors) can also assist. See the Government’s guidance on different IDV routes here.
How should I prepare? The changes above should be factored into any upcoming deal timelines, particularly if new directors, LLP members, or PSCs are envisaged around 18 November, so as to ensure compliance with IDV requirements as well as notification obligations to Companies House. Companies with confirmation statement deadlines which fall not long after 18 November should also consider voluntarily completing IDV as soon as possible and potentially in advance of the compulsory period start date. Failure to comply with the requirements for IDV and information filing may result in the individual and/or the company committing a criminal offence.
If you would like further information on ECCTA, see our Linklaters Economic Crime and Corporate Transparency Hub which brings together cross-practice expertise and commentary on the different aspects of the Act. See the regulations on IDV and registers here and on the registrar’s duty to annotate the register here.
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