Guide
When do directors have to verify their identity?
Updated
There is no single director deadline, which is why so much of the coverage is wrong. Your date is your company's confirmation statement date, and you have one for every company you sit on.
The trigger
Companies House states that a director will need to provide their Companies House personal code as part of the company's next confirmation statement, and that if you are a director of more than one company, you need to do this for each company (gov.uk). It also states that your company will be unable to file its confirmation statement unless all its directors are verified. In a company with several directors, that turns an individual obligation into a collective blocker, and the person who notices is usually whoever tries to file.
The other three director triggers
- Being appointed to an existing company
- Provide the personal code as part of your appointment filing. In practice, verification has to be complete before the appointment can be filed.
- Incorporating a new company
- Companies House asks for the personal code for each director as part of the registration filing. Every proposed director must have verified before you can incorporate.
- Overseas company registered in the UK
- Confirm that all directors have verified their identity by the anniversary of your UK establishment's registration. This is a different, easily missed trigger with no annual filing habit attached.
The transition, and what it is not
The government's campaign site states that from 18 November 2025 identity verification becomes a legal requirement, and adds directly: this date is not a deadline. It marks the start of a 12-month transition period, giving companies time to make sure all directors and PSCs have verified by their due dates (gov.uk campaign site). Read that carefully in both directions: nobody was in breach on 19 November 2025 simply for not having verified, and equally nobody gets until November 2026 if their confirmation statement falls sooner.
If you do not verify
- Companies House states it is unlawful for a director to act as a director without completing identity verification, and that the company may also be breaking the law.
- Directors and equivalents may be committing an offence under section 167M of the Companies Act 2006 for continuing to act without verification, and the company may be in breach for failing to rectify it.
- Enforcement routes are prosecution through court, referral to The Insolvency Service, and financial penalties, and other methods include annotating the register and director disqualification.
- Companies House is likely to treat non-compliance as serious where a person or company has committed 3 or more offences over a 5 year period.
- You will also be unable to be appointed as a new director, register a new company, or register as an ACSP.
If there are genuinely exceptional circumstances, Companies House operates a representations process. It states it will consider representations only within the timeframe given, that the decision is final, and that where accepted it usually pauses enforcement for up to 2 months. Its example of an acceptable case is a serious IT failure at the time the statement was due, with no other way to complete the task.