The Companies House verification deadline and what follows a miss

The date, and the mechanism it arms

18 November 2026 is the end of the transition period for identity verification at Companies House. It is not the start of the regime. New directors and persons with significant control (PSCs) have been within the requirement since 18 November 2025, under the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023). What closes on 18 November 2026 is the twelve-month window given to directors and PSCs who were already on the register on that earlier date. After it, an unverified identity is not a pending task. It is a defect in the company's ability to file.

The requirement itself is defined in statute. Section 1110A of the Companies Act 2006 sets out what it means for an individual's identity to be verified, and the procedure is fixed by The Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025 (SI 2025/50). Verification is completed once and produces an eleven-character personal code, in the form ABCD-1234-EFGH. The code is the register's proof that the person behind an appointment is who they claim to be.

The reason the date matters is not the verification itself. It is what verification has been wired into.

Section 853A: verification is now a filing gate

The confirmation statement, filed on form CS01, is the annual declaration that a company's registered information is accurate. It is not optional and it is not occasional. A confirmation statement must be delivered within 14 days of the end of the company's review period, and delivery is the event that keeps the company in good standing on the register.

ECCTA 2023 amended section 853A of the Companies Act 2006 so that a company cannot make a confirmation statement while any of its directors or PSCs remains unverified. The filing and the verification are now a single dependency. One unverified officer holds the whole statement.

This is the point most affected companies underestimate. Verification is often treated as a personal administrative errand for each director, to be done at some convenient point. Section 853A converts it into a corporate filing condition. A company with an unverified overseas director does not have an inconvenienced director. It has a confirmation statement it cannot deliver, and a 14-day statutory window that closes regardless.

Why the free route fails the people closest to the deadline

The free government route is GOV.UK One Login. It works by scanning a chipped passport or a UK photo driving licence with a smartphone, then matching the applicant's face to the document. Where the applicant is a UK resident with a chipped passport and a UK financial record, it is quick and it is free, and it is the correct choice.

The route depends on two things that a large share of legitimate directors do not have: a recognised UK photographic document, and a UK digital record such as a bank account or credit history against which the person can be checked. An overseas director with a valid non-UK passport and no UK footprint is frequently rejected with no reason given and no clear next step. The reasons this happens, and the mechanics of the fallback checks, are set out in the companion analysis of Companies House identity verification for overseas directors. The pattern is consistent: the further an applicant sits from the profile of a typical UK resident, the more likely the automated route is to stop working.

The cruelty of the timing is that the people the free route rejects, overseas directors and non-resident PSCs, are also the people whose companies most often depend on a single such officer to file. The verification failure and the filing failure land on the same entity.

The cascade after a blocked filing

A blocked confirmation statement is not a static problem. It decays.

• Strike-off. A company that cannot deliver its confirmation statement is exposed to compulsory strike-off by the Registrar. Dissolution ends the company's legal existence, and its assets, including bank balances and property, pass to the Crown as bona vacantia.
• Banking and AML freezes. UK financial institutions monitor Companies House data as part of continuing customer due diligence. An unverified director, an unverified PSC, or a company that has failed to file reads as a risk flag. Accounts can be frozen and facilities suspended well before any strike-off is formally proposed, which is often the first hard consequence a business actually feels.
• Personal criminal exposure. Acting as a director while unverified, or filing on a false basis, is not a neutral act. Under section 1112 of the Companies Act 2006 a person who, without reasonable excuse, delivers a misleading, false or deceptive statement to the Registrar commits an offence. Section 1112A creates an aggravated offence for a person who does so knowing the statement to be misleading, false or deceptive, which on conviction on indictment carries imprisonment for up to two years, a fine, or both. Section 1112B provides a narrow national-security defence that has no application to ordinary commercial actors.

Each stage feeds the next. The filing block is administrative, the banking freeze is operational, and the criminal exposure is personal. A company can be trading normally in October and dealing with a frozen account and a strike-off notice by the following spring, on nothing more than one director who could not complete a face scan.

The Authorised Corporate Service Provider as the statutory route through

The legislation anticipated that the automated route would not reach everyone, and it built a second, formal route rather than leaving a gap. Section 1098A of the Companies Act 2006 establishes the Authorised Corporate Service Provider (ACSP): a firm registered with Companies House and supervised under the UK Money Laundering Regulations, authorised to verify an individual and deliver the verification statement to the Registrar directly.

An ACSP is not a workaround. It is the alternative verification channel written into the same regime, and it reaches the identical eleven-character personal code by a different evidential path. Where the free route relies on automated document validation and a UK credit query, an ACSP verifies against the standards in SI 2025/50 and can accept a wider combination of documents, including a non-UK passport with or without a biometric chip, supported by independent evidence of address. For a director the automated route has already rejected, this is the difference between holding a code and being unable to obtain one.

The regime holds the ACSP to account for that trust. The provider is required to retain the identity evidence for seven years and carries regulatory liability for the verification it certifies. The verification is human-reviewed rather than left to a facial-recognition algorithm that has three attempts and then locks the applicant out.

Latency is the variable that decides the outcome

Being authorised to act as an ACSP and being able to act in time are two different things. Every large institutional registrar, multinational law firm and major accountancy network is authorised under section 1098A. Few are built to run a single standalone identity verification quickly. Their onboarding is designed for full-service engagements: conflict checks, risk committees, and customer due diligence frameworks measured in weeks.

Against a 14-day confirmation statement window, or the separate window for a new PSC, an onboarding process measured in weeks is a refusal in all but name. A verification that arrives after the filing deadline does not save the filing. This is the practical reason boutique and partner-led providers, which productise the verification into a defined, fast process, are the ones that resolve these cases inside the statutory windows. The relevant question when instructing a provider is not whether the firm is an ACSP. It is how quickly the firm will actually complete the verification and file the statement.

For a PSC who is not a director, the window is tighter still, and the analysis of how the personal code connects to each separate role sits in the companion note on the verification routes. A code that is obtained but never connected to the role leaves the obligation unmet.

How Boru can assist

Boru Global (UK) Limited is a registered Authorised Corporate Service Provider, listed on the GOV.UK register of ACSPs as ACSP Agent No. AP000267. We verify directors and PSCs wherever they are located, accept documentation the free service refuses, deliver the verification statement to the Registrar, and connect the resulting personal code to the confirmation statement and any related filing, so that verification is completed rather than merely started. For a company with an unverified officer and a filing window closing, that is the specific problem we resolve.

An unverified director is not a paperwork problem. It is a dissolution timer, and section 853A is the switch that starts it.

Frequently asked questions

What is the Companies House identity verification deadline for 2026?

18 November 2026 is the end of the twelve-month transition period under the Economic Crime and Corporate Transparency Act 2023. By that date, every director and person with significant control who was already on the register must hold a verified identity. New directors and PSCs have been required to verify since 18 November 2025, so from the 2026 date the requirement applies to the entire population of existing officers.

What happens if a director is not verified by 18 November 2026?

The company cannot deliver its confirmation statement, because section 853A of the Companies Act 2006 makes filing contingent on all directors and PSCs being verified. A confirmation statement not filed within 14 days of the end of the review period exposes the company to compulsory strike-off, and the unverified status can trigger bank account freezes under anti-money-laundering monitoring before strike-off is reached.

Can an unverified director block a company's confirmation statement?

Yes. Under the amended section 853A, a single unverified director or PSC prevents the whole company from delivering its confirmation statement. The obligation is corporate, not personal to the individual, so one officer who has not completed verification holds the entire filing and puts the company's standing on the register at risk.

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

The free route relies on a recognised UK photographic document and a UK digital record such as a bank account or credit history. An overseas director with a valid non-UK passport and no UK footprint is often rejected with no reason given, because the fallback checks assume a UK history the applicant does not have. This is why non-resident directors are the group most often turned away.

What is an Authorised Corporate Service Provider?

An Authorised Corporate Service Provider (ACSP) is a firm registered with Companies House and supervised under the UK Money Laundering Regulations, authorised under section 1098A of the Companies Act 2006 to verify a person's identity and deliver the verification statement to the Registrar. It can verify an individual in any country, accept a wider range of documents, and produces the same eleven-character personal code as the free route.

What is the eleven-character personal code?

It is the code produced when identity verification is completed, in the form ABCD-1234-EFGH, defined through section 1110A of the Companies Act 2006 and the 2025 Regulations. The code is personal to the individual and obtained once, and it is then connected to each role the person holds, whether as a director, a PSC, or both, to satisfy the register.

What are the criminal penalties for false verification statements?

Under section 1112 of the Companies Act 2006, delivering a misleading, false or deceptive statement to the Registrar without reasonable excuse is an offence. Section 1112A creates an aggravated offence where the person knows the statement is false, and on conviction on indictment it carries imprisonment for up to two years, a fine, or both. A narrow national-security defence exists under section 1112B but does not reach ordinary commercial cases.

Is an ACSP faster than a Big Four firm for verification?

Usually, yes, for a standalone verification. Large institutional firms are authorised as ACSPs but their onboarding, conflict checks and risk reviews are built for full engagements and often run for weeks, which does not fit a 14-day filing window. Boutique and partner-led ACSPs that treat verification as a defined process are generally the ones that complete it and file the statement inside the statutory deadline.