Director Identity Verification Requirements 18th November 2026

The 18th of November 2026 marks the end of the 12-month transition period for mandatory identity verification at Companies House, and for many accountants that are managing company secretarial compliance, it’s the date when enforcement action will escalate. If your clients haven’t completed their identity verification requirements by then, they may face consequences such as financial penalties, prosecution, director disqualification, and potentially removal from the register.

What’s Happening on 18th of November 2026?

From the 18th of November 2025, identity verification became a legal requirement under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). This marked the start of a 12-month transition period. By the 18th of November 2026, all existing company directors and people with significant control (PSCs) must have verified their identity and provided their Companies House personal code to the Registrar.

According to Companies House guidance, approximately 6 to 7 million individuals across the UK will need to complete this process. For many clients, this will happen as part of their next confirmation statement filing. For PSCs, it means providing a personal code within their personal 14-day window.

The deadline itself isn’t new, but what changes on the 18th of November 2026 is Companies House’s enforcement posture. After this date the transition period ends and the regulator moves from a primarily support and guidance phase into more active enforcement.

The Consequences of Non-Compliance

Companies House has published a detailed approach to non-compliance with mandatory identity verification, which outlines exactly what happens when directors or PSCs fail to verify their identities.

Financial Penalties: Companies House may issue financial penalties at company or individual officer level. These are separate from any other fines or sanctions.
Prosecution: In serious cases where a person or company has committed three or more offences over a five-year period, Companies House could consider criminal prosecution. This can lead to director disqualification and substantial court fines.
Continuing in Breach: If a director continues to act without identity verification after the deadline, they are committing an offence under section 167M of the Companies Act 2006. The company is also in breach. Companies House sends default letters outlining these offences and may refer cases to The Insolvency Service.
Company Removal: If a company fails to comply, it may be struck off the register or removed for non-compliance.

It’s not just the individuals at risk. The company itself can be in breach if one of its directors has failed to verify their identity. This creates dual liability where both the director and the company are breaking the law.

The Confirmation Statement Connection

For most existing directors, identity verification happens during the confirmation statement (CS01) filing process. Filing guidance on Companies House makes clear that directors must provide their personal code as part of the next confirmation statement filed from 18th of November 2025.

You cannot file a confirmation statement without confirming that all directors have verified their identities. For accountants managing confirmation statements, this creates a challenge as you need to identify which directors have not yet verified, nudge them to complete verification, and then include the personal code in the CS01 submission.

What Actionable Steps Can You Take for Your Firm?

Pull a list of every company you manage. Log into Inform Direct and check which directors and PSCs have not yet verified. The software automatically flags directors and PSCs who need verification using reports that help you identify who needs to have checks completed.

Make sure you track:

Each director’s name and verification status
Each PSC’s name and verification status
Confirmation statement filing date
Verification statement due dates for PSCs
This audit reveals your immediate risk exposure. Any director or PSC not verified creates personal liability for that individual and breach liability for the company.

Contact clients with confirmation statement filing deadlines before the 18th of November 2026. Use Inform Direct’s filing deadline monitoring feature to see deadlines at a glance for all your companies. These companies cannot file confirmation statements without providing director personal codes.

Send formal written notification to each client with unverified directors and PSCs.

Make sure to include:

The specific names of people who need to verify
The legal requirement and section reference (ECCTA 2023)
The deadline
How verification works
The personal code they’ll receive after verifying
Your role as ACSP if applicable
Specific consequences
Your deadline for receipt of personal codes

Make the communication formal and dated so you have evidence you warned them. Use Inform Direct’s secure document library to store all client communications for audit and compliance purposes. Follow up in writing if clients don’t respond.

Self-verify via GOV.UK
Verify at Post Office
You verify them as an ACSP if registered. With Inform Direct, you can launch identity verification checks for your clients at the touch of a button and receive the results and personal codes directly. This costs £4-5 + VAT per check, gives you control over the process, and provides immediate evidence of completion.

Many accountants find Option 3 generates additional compliance revenue while protecting clients because you are the one handling verification and hold evidence of completion within Inform Direct’s secure system.

Before drafting any confirmation statement, obtain personal codes from all directors. Inform Direct automatically flags which directorss need verification. When you prepare the confirmation statement, the software will not allow you to file without including personal codes for all directors.

You’ll also need to be mindful of the verification dates for the company’s PSCs. The verification window for some PSCs falls within 14 days of the confirmation statement date, whereas for others it is in line with the first 14 days of the PSC’s month of birth.

Inform Direct automatically includes personal codes in the CS01 filing. If a director hasn’t provided their personal code by your filing deadline, the software will prevent incomplete filing. Contact the company to complete verification before filing the confirmation statement.

Keep a complete file for each company. Inform Direct’s document library securely stores all client communications and evidence.

Make sure to store:

Written communications showing when you notified clients of verification requirement
Dates you received personal codes from each director and PSC
Records showing which verification method they used
Copies of confirmation statements showing personal codes were included (Inform Direct generates these automatically)
Evidence the company filed on time

This documentation protects you if enforcement action occurs. It shows you acted professionally and any breach was the client’s failure to comply, not yours.

Manual tracking of verification status for dozens or hundreds of companies is error-prone and time-consuming. Inform Direct handles the entire verification tracking and filing process. The software automatically identifies which directors and PSCs need verification, flags them in the system, includes personal codes in CS01 filings automatically, and produces all required documents including compliant templates for director appointments, terminations and changes.

For firms managing company secretarial work at scale, this automation prevents directors from slipping through the cracks and ensures every confirmation statement includes required verification details. The software also maintains your statutory registers automatically, updating them as verification and other changes are made.

Timeline for Action

Now (September 2026), audit all clients using Inform Direct and send outstanding verification notices
Before the 18th of November 2026, make sure you file all confirmation statements with codes included through Inform Direct
The 18th of November 2026 is when enforcement is likely to accelerate
After the 18th of November 2026, we expect Companies House to pursue financial penalties and prosecution for non-compliance

Act Now

This deadline demands urgent attention. Start auditing your client portfolio this week using Inform Direct. Communicate with clients this month. Put systems in place to integrate verification into your confirmation statement workflow by October using Inform Direct’s automated features.

Your clients’ directors will thank you when they avoid Companies House enforcement action altogether.

This content may have been developed with the assistance of AI tools. Content is reviewed by a member of the Bright team before publication. Guidance on legislation can be obtained from your industry body.