Companies House identity verification is not the same for everyone

For some it takes minutes, for others it does not work at all

For some company directors, verifying their identity with Companies House takes only a few minutes. For others it is a process of repeated failure over several weeks. The difference often comes down to something as small as whether a passport contains a biometric chip, and whether the individual has a UK credit history.

The free government service works well for a UK resident who holds a chipped passport or a recent photo driving licence and has an established UK financial record. For anyone outside that profile it can stop working with little explanation. A significant number of legitimate directors and persons with significant control (PSCs), particularly those based overseas, fall outside it.

This note explains why the difference arises, and the options for those in the second group.

The requirement and the personal code

The requirement itself is straightforward. Since 18 November 2025, under the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023), directors and PSCs must verify their identity with Companies House. New directors and PSCs are in scope from that date, and existing officers are brought in over a 12-month transition period tied to their due dates rather than by a single deadline. Verification is defined through section 1110A of the Companies Act 2006 and the Registrar's Regulations 2025, is completed once, and produces an eleven-character personal code.

The difficulty lies not in understanding the requirement but in completing it, which is considerably easier for some people than others.

Two routes to a personal code

There are two ways to reach the same personal code.

GOV.UK One Login is the free government route. The applicant scans a chipped passport or UK photo driving licence using a smartphone with near-field communication, then photographs their face for matching. Where it works, it is quick and carries no charge.

An Authorised Corporate Service Provider (ACSP) is the alternative. An ACSP is a firm registered with Companies House and supervised for anti-money-laundering purposes, authorised under section 1098A of the Companies Act 2006 to verify an individual and confirm that verification to Companies House directly. The legal outcome is the same personal code, reached by a different route.

For a UK resident with a chipped passport and a current smartphone, One Login is free and adequate, and is the sensible choice. This note is concerned with those it does not serve well.

Where the free route fails

One Login depends on two things: a recognised UK photographic document, and a digital record against which the applicant can be checked, such as a UK bank account or credit history. Where either is missing, the experience ranges from inconvenient to a complete barrier.

The reported difficulties are consistent. Directors based overseas describe scanning a valid non-UK passport and their face, only to be told that their identity cannot be proven, with no reason given and no clear next step. Individuals without a passport or driving licence cannot progress, because the fallback identity questions assume a UK financial history they do not have.

The pattern is the same throughout: the service is designed around a typical UK resident, and the further an applicant sits from that profile, the more likely it is to fail. Overseas directors are affected most often, and are frequently those under the greatest time pressure.

Where an ACSP is the more practical route

For applicants the free route cannot accommodate, an ACSP addresses the specific points of failure.

• It can verify an individual located in any country, without reliance on a UK credit record.
• It accepts a wider range of documents, including non-UK passports and identity documents, with or without a biometric chip, using identity-document validation technology.
• A named contact handles the matter, in place of an automated service and a general queue.
• Several directors and PSCs within the same company can be managed together.

For an individual the free route has already rejected, this is the difference between completing verification and being unable to do so.

Obtaining the code is not the final step

The personal code does not, by itself, update the register. It has to be connected to each role the individual holds, and the method and timing differ by role.

• A director provides the code on the company's next confirmation statement, which may not fall due for some months.
• A person who is both a director and a PSC must additionally provide the code for the PSC role through a separate service, within 14 days of the confirmation statement date.
• A PSC who is not a director provides the code within the first 14 days of their birth month, with a potential penalty for late filing.
• A director of an overseas company has a further filing, form OS VS01, which deals with this stage.

A verification that produces a code but is never connected to the relevant role leaves the obligation unmet. The code is the start of the process on the register, not the end of it.

Enforcement has already begun

The requirement is being enforced, not merely stated. On 16 September 2026 the Insolvency Service secured its first convictions for identity verification offences at the City of London Magistrates' Court, fining directors who had acted while unverified and, in one case, a director who had verified himself but allowed an unverified colleague to continue acting. The companies had also failed to file a confirmation statement on time, the filing that section 853A of the Companies Act 2006 now makes contingent on every director and PSC being verified.

The fines were modest, £166, £307 and £80 with costs of £85 in each case, but the conviction is the consequence that carries, because a director with a criminal record for a filing offence is a different proposition to a bank or a counterparty than one without. The cases were brought before the 12-month transition period had even closed. The mechanics of the deadline, and what a blocked confirmation statement sets in motion, are set out in the companion note on the verification deadline and what follows a miss. For an overseas director still unable to complete the free route, the practical point is that the window to resolve it is finite and the cost of leaving it is no longer hypothetical.

Choosing between the two routes

• A UK resident with a chipped passport and a smartphone should use One Login.
• An individual based overseas, holding non-standard documents, or without an established UK financial record, is generally better served by an ACSP.
• A company with several officers to verify, or one that prefers the matter handled and filed in full, is also better served by an ACSP.

Frequently asked questions

Who has to verify their identity with Companies House?

Every UK company director and every person with significant control (PSC) must verify their identity, under the Economic Crime and Corporate Transparency Act 2023. The requirement also reaches people who file information with Companies House. It applies regardless of where the individual lives, so an overseas director of a UK company is within scope in the same way as a UK-resident director.

When did Companies House identity verification become mandatory?

The requirement came into force on 18 November 2025. From that date, anyone newly becoming a director or PSC must verify their identity. For directors and PSCs already on the register, that date marked the start of a 12-month transition period, during which each existing officer has to verify by their own due date rather than all at once.

What is a Companies House personal code?

It is the eleven-character code produced when an individual completes identity verification. The code is personal to the individual, is obtained once, and is then used to confirm verification against each role the person holds, whether as a director, a PSC, or both. You should not verify again once you have a code unless Companies House asks you to.

What are the two ways to verify my identity for Companies House?

The free route is the GOV.UK One Login app, where you scan a chipped passport or UK photo driving licence with a smartphone and photograph your face for matching. The alternative is an Authorised Corporate Service Provider (ACSP), a firm registered with Companies House and supervised for anti-money-laundering purposes that verifies you and confirms it to Companies House directly. Both produce the same personal code.

Why does GOV.UK One Login fail for some overseas directors?

One Login relies on a recognised UK photographic document and a UK digital record, such as a bank account or credit history, against which the applicant can be checked. An overseas director with a valid non-UK passport and no UK financial footprint often has the scan and face match rejected with no reason given, because the service is built around a typical UK resident and its fallback checks assume a UK history the applicant does not have.

What is an Authorised Corporate Service Provider (ACSP)?

An ACSP is a firm registered with Companies House and supervised for anti-money-laundering purposes that is authorised to verify an individual's identity and confirm that verification to Companies House. It can verify a person located in any country, accept a wider range of documents including non-UK passports with or without a biometric chip, and provide a named contact rather than an automated queue. The personal code it produces is the same one the free route produces.

When does a PSC who is not a director have to verify?

A PSC who is not also a director must provide their personal code within the first 14 days of the month in which they were born. For example, a PSC born on 20 March has a 14-day window beginning on 1 March. Late filing can attract a penalty, so for an overseas PSC who cannot use the free route, leaving verification until the birth month is a risk.

How does a director of an overseas company verify their identity?

A director of an overseas company that is registered in the UK still has to verify, and there is a dedicated filing for it, form OS VS01, which is used to provide directors' identity verification for the overseas company. Because overseas directors are also the group most likely to be turned away by the free route, this is a common case for using an ACSP, which can both verify the individual and attend to the related filing.

---

Critical advisory. Companies House identity verification is not a uniform task. It is quick for a UK resident with a chipped passport and a UK financial record, and a repeated dead end for an overseas director with neither.

The personal code is only the start, because it then has to be connected to each role, a director on the next confirmation statement, a PSC who is not a director within the first 14 days of their birth month, and an overseas company director on form OS VS01, and a code obtained but never connected leaves the obligation unmet.

We are a registered Authorised Corporate Service Provider (Agent No. AP000267) and verify directors and PSCs wherever they are located, accept documents the free route refuses, and connect the code to the relevant filings so that verification is completed rather than merely started. This article is general information and not legal advice, and your own position should be confirmed against your specific facts before you act.