ECCTA 2023: company directors and IDV… where are we now?

What is the objective of the Economic Crime and Corporate Transparency Act (ECCTA) 2023 with regards to identity verification? ‘[To] prevent organised criminals, fraudsters, kleptocrats and terrorists from using companies and other corporate entities to abuse the UK’s open economy’.

We are six months into the phased introduction of identity verification (‘IDV’) checks for individuals at Companies House. In this first half year, we have seen various issues arise with the regime such as director information anomalies, not helped by Companies House’s diminished response time. Below we highlight some of the common issues that have arisen during the early phase of the IDV regime, provide some practical guidance for companies on how to resolve them and consider what’s next for IDV.

What is identity verification?

As a brief recap, the ECCTA introduced the requirement for directors and persons with significant control (‘PSCs’) to verify their identity with Companies House which became mandatory on 18 November 2026.

An individual can verify their identity through the Companies House website in combination with the GOV.UK ID Check app on a mobile phone. If an individual does not have access to a computer and/or a mobile, their identity can be verified at the Post Office.

Once an individual’s identity has been verified then they will receive a unique identifier code (or ‘UI Code’, also called an IDV code).

Currently, only directors and individual PSCs need to verify their identity, but Companies House intends to enforce the same for company secretaries, representatives of a relevant legal entity (‘RLE’) and all persons filing forms at some point in the future (date to be confirmed).

How/when to tell Companies House the UI Code?

Existing directors: companies are required to record the UI Code for each of their directors on an IDV statement which is filed with the companies next confirmation statement (‘CS01’). Failure to add the UI Codes will cause Companies House to reject the CS01. For more information on this process please see our previously published article.

If an individual holds multiple directorships, their UI Code will need to be disclosed to each company for inclusion in their confirmation statements.

New directors: since 18 November 2025, a director’s UI Code must be included when their appointment is filed at Companies House (using Form AP01) or when the company is incorporated.

Common issues arising from the IDV process

Director information

All individuals verifying their identity with Companies House must ensure their name and date of birth recorded on all appointments exactly matches that on the identification document used to verify their identity. Due to the sensitivity of the UI Codes, any mismatches are likely to cause the rejection of the forms being filed.

International directors

We have seen various issues with international directors of UK companies trying to verify their identity.

One such issue was directors physically outside of the UK were not receiving the text messages from Companies House to progress with the verification process, though we understand from Companies House that this issue has now been resolved.

Other problems arise from the form of ID needed for the IDV checks, such as a passport with the biometric chip. Unfortunately, if an individual does not have the required form of ID, they still need to find an alternative method of verifying their identity.

The effect

Failure to successfully complete the IDV checks may delay filing of the company’s CS01, which then runs the risk that the Registrar submits a petition to strike off the company from the register if the CS01 is not filed.

The solutions

Correcting the information on the register

If the appointment information recorded on the register is incorrect, there is a process to amend that information, but if it is necessary to file the amendments on paper, please note there is currently a delay of several weeks for the Registrar to process them.

If a director’s name(s) cannot be corrected before the company’s next CS01 filing deadline or the name is not necessarily incorrect, but is a preferred name, Companies House provides the option to register the individual’s UI Code on the appointment form or CS01 with a name ‘discrepancy’. It is best practice to proceed with correcting the name after the filing, as it may be something Companies House picks up later, but this is useful to avoid late filing penalties in the first instance.

Representations to extend the filing deadline

If a company is unable to file its CS01 due to issues with directors’ UI Codes, it can make a representation to Companies House to extend the filing deadline. The representation can only be made once the company’s CS01 has become overdue and must be submitted to Companies House within 28 days from receiving the default (overdue) notice. If the representation is accepted by Companies House, there will be a new filing deadline confirmed.

Verifying identity with an Authorised Corporate Service Provider (ACSP)

If an individual is struggling to verify their identity through the Companies House website, a registered ACSP may be able to help. An ACSP must be authorised by a UK anti-money laundering supervisory body and Companies House provides a list for current and suspended/ceased ACSPs.

Not all ACSPs deal with IDV checks, but those that do may be a solution to any issue a director or PSC has.

It is worth noting that approximately 144 ACSPs have been suspended or ceased to be an ACSP since 18 November 2025, in some cases because they have not complied with the legal requirements when verifying identities.

Blake Morgan is registered an as ACSP, but we do not undertake IDV checks. However, we can refer you to an alternative ACSP if you need assistance with verifying your identity with Companies House.

The proposed changes to come

Corporate directors

Restrictions will be put into place which will require corporate directors to have an all-natural person board, for whom UI Codes need to be obtained. Only UK corporate entities with legal personality will be capable of acting as a corporate director.

The Registrar’s new powers for disqualified/unverified directors

By the end of 2026, Companies House aim to be able to reject documents delivered by disqualified directors, unless they are delivered by an ACSP for specified filings permitted by law.

In the same period, the IDV process will have been completed, and Companies House will begin to follow up with individuals who have failed to undertake their IDV checks.

So… where are we now?

Whilst the initial issues with the IDV process are gradually being ironed out, the effects are still very much present with the services provided by Companies House.

The Registrar has previously confirmed that for the period from January to March 2026, 28.49% of positions have now been verified. Now, in the third progress report published since the implementation of the ECCTA, Companies House is said to have issued 3.81 million UI Codes which have been linked to 3.74 million appointments.

Interestingly, in the same progress report published on 11 June 2026, a statistic was given that there has been a 68% increase in accepted director changes compared to the same time in 2024, suggesting an increase in the reliability of director information on the register.

Companies House also have an ECCTA outline transition plan which sets out, in brief, the expected next steps and when they are likely to be implemented. The plan is periodically updated and a good source for your company to account for future changes.