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Mandatory identity verification

19.11.2025

5 minute read

Authored by

Greg Vincent

Partner, Head of Department

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Mandatory identity verification – starts this week

Mandatory identity verification (“IDV”) requirements formally come into force on Tuesday 18 November 2025, marking a significant shift in corporate governance and transparency obligations for UK companies and limited liability partnerships (LLPs).

These reforms are part of the broader modernisation of Companies House and are designed to strengthen the integrity of the public register.

Who must complete identity verification?

From 18 November 2025, the obligation to complete IDV applies to the following categories of individuals:

  • Company directors
  • Members of LLPs
  • Persons with Significant Control (PSCs) who meet the statutory thresholds

IDV will be a mandatory prerequisite to holding or continuing in any of these roles.

Companies and LLPs should ensure that all relevant individuals are aware of their duties and prepared to complete verification promptly.

Duties on new PSCs

Any individual who becomes a registrable PSC on or after 18 November 2025 must inform the company or LLP whether they have already completed the IDV process.

If they have not completed verification, Companies House will contact them directly and require them to do so within a prescribed timeframe.

Similarly, new company directors and LLP members appointed after 18 November 2025, will have to carry out IDV as part of their appointment.

Transitional provisions for existing officeholders

Individuals who, immediately before 18 November 2025, already held a position as a Company Director, LLP member or registrable PSC, will be subject to transitional IDV deadlines, rather than needing to complete verification immediately on the implementation date.

These transitional rules assign each individual a specific personal deadline, based on which role(s) they occupy.

Broadly speaking, for existing directors and LLP members, they will have until the next confirmation date on which the company or LLP has to submit its annual filing at Companies House to complete IDV.

Companies House will continue to provide further direction on how these deadlines apply in practice. Organisations should review their existing officeholders and PSCs now to ensure timely compliance.

How to complete identity verification

Companies House has published detailed guidance setting out:

  • The steps in the verification process,
  • The types of ID that can be used,
  • How to use authorised agents for verification, and
  • How Companies House will process and confirm verified status.

We can provide tailored advice and walk individuals through the verification options if required.

Abolition of internal statutory registers

Also, effective 18 November 2025, companies and LLPs will no longer be legally required to maintain a number of internal statutory registers. These include:

For companies:

  • Register of directors
  • Register of directors’ residential addresses
  • Register of secretaries
  • PSC register

For LLPs:

  • Register of members
  • Register of members’ residential addresses
  • PSC register

This marks a significant modernisation of corporate record-keeping requirements.

Should companies and LLPs maintain internal records anyway?

Although statutory registers are being abolished, organisations may still choose to keep internal, non-statutory registers as part of good governance and administrative practice. Doing so can continue to support internal record-keeping, due diligence, audits and transactional needs.

However, growingly, the official source of truth will be the information filed at Companies House. Third parties, including lenders, investors, counterparties and regulators, will seek to rely on the public register to:

  • Confirm the identity of directors and secretaries
  • Verify LLP members
  • Identify PSCs

This makes timely, accurate filing with Companies House more important than ever.

Key actions for companies and LLPs

  1. Notify all directors, LLP members and PSCs of their IDV obligations
  2. Identify individuals subject to transitional deadlines and prepare them accordingly
  3. Review internal processes to ensure prompt and correct filing of updates to Companies House
  4. Decide whether to maintain internal non-statutory registers for governance purposes
  5. Seek guidance where uncertainties arise, particularly for complex ownership or control structures

How can Morr & Co help?

If you have any questions or would like any further information on the content of this article, please do not hesitate to contact our Corporate and Commercial Law team on 0333 038 9100 or email info@morrlaw.com and a member of our expert team will get back to you.

Disclaimer
Although correct at the time of publication, the contents of this newsletter/blog are intended for general information purposes only and shall not be deemed to be, or constitute, legal advice. We cannot accept responsibility for any loss as a result of acts or omissions taken in respect of this article. Please contact us for the latest legal position.

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