The Code Before the Confirmation Statement: Director Identity Checks for the 2026 Filing Round
Photo: small company director reviewing identity documents at office desk UK, via petsaustralia.com.au
For most of the register's history, Companies House took declarations largely on trust. A name went on the record, a confirmation statement followed each year, and the machinery turned. That approach has been replaced by something more deliberate. Under powers introduced by the Economic Crime and Corporate Transparency Act 2023, identity verification has moved from an optional extra to a condition of taking part in the filing cycle. For a small company with two directors and a single shareholder, the practical effect is modest but unforgiving: someone must complete a short digital check, and the paperwork cannot proceed cleanly until they have.
The requirement was phased in. Voluntary verification opened in March 2025, and from 18 November 2025 it became mandatory for newly appointed directors and people with significant control. Directors already in post are drawn into the process when they next file a confirmation statement. By the 2026 filing season, most small firms will therefore meet the requirement not as a future reform but as a live task on the calendar.
Who is caught by the requirement
The obligation attaches to individuals, not to companies. A director of a private limited company must verify. So must a person with significant control, which in a typical owner-managed business usually means the same person wearing a second hat. Members of limited liability partnerships fall within scope, as do general partners in limited partnerships. Company secretaries are not caught unless they also hold one of the in-scope roles.
The check belongs to the person, not the appointment. Once an individual has verified, that verified status can be relied upon across every company where they act, which is welcome news for anyone with several directorships. What cannot happen is verification by proxy: a spouse, an accountant or a fellow director cannot complete the check on someone else's behalf. Nor can a company verify itself.
What the check actually involves
The standard route is free and runs through GOV.UK One Login. In outline, the individual creates or reuses a One Login account, confirms their identity using a smartphone, and links that confirmed identity to their Companies House record. The process typically asks for a valid photographic identity document, such as a passport or photocard driving licence, together with a short liveness check and some address history. There is no postal application and no need to send original documents anywhere.
The second route is through a Companies House authorised agent, sometimes referred to as an ACSP. This is designed for people who cannot use the standard digital path, whether because of the documents they hold, a lack of compatible technology, or simply a preference for handing the task to a professional. Agents must themselves be registered and supervised, and their services are commercial, so fees apply.
Whichever route is used, the output is the same: a personal code issued to the individual. That code is the evidence the company needs when it comes to filing.
Where delays usually begin
The check itself takes minutes. The problems tend to arise from mismatches between the person and the record.
Names that have drifted. A director registered as "Elizabeth" who now uses "Liz", or who has married since appointment and holds a passport in a different surname, will often find that the automated matching falters. Middle names omitted at incorporation are a recurring irritant. The fix is not complicated, but it needs doing before the deadline rather than on it.
Expired or unsuitable documents. A passport that expired last month, or a licence without a current photograph, will not pass. Neither will a document in a name that differs from the register without supporting evidence of the change.
Poor conditions for the liveness check. Glare, a dark room or a low-quality phone camera can produce repeated failures that look like a system fault but are simply environmental.
One Login already in use. Accounts created for other government services sometimes carry details that conflict with the Companies House record. Reconciling them is straightforward but rarely same-day.
Gaps in the governance chain. Where a director has died, resigned without notification, or cannot be contacted, the company faces a more involved problem. The answer is an early conversation with Companies House rather than a speculative filing.
Overseas directors are not exempt. Verification is available to non-UK residents, but the accepted document set narrows and the agent route becomes more attractive. Allow additional time.
Sequencing verification against the filing calendar
The confirmation statement is the pinch point. Identity verification must be confirmed in respect of the directors and PSCs at the point of filing; a statement submitted before the individuals are verified is liable to be rejected. Accounts filed under the small company regime do not in themselves trigger the check, but they sit in the same window and compete for the same attention.
A sensible order of work looks like this:
- Audit the register. Pull the current list of directors and PSCs, with full names exactly as recorded.
- Check documents now. Confirm each person holds valid photographic ID in a name that matches, or that any discrepancy is documented.
- Decide the route. Standard One Login for most; agent route booked early where documents are irregular or the individual is overseas.
- Verify well ahead. Aim to have every code in hand at least a month before the confirmation statement falls due. Verification does not lapse annually, so this is a one-off cost in time.
- Record the outcome. Keep the personal code, the date of verification and, where an agent was used, the agent's details with the company's statutory records.
- File the confirmation statement. Only once verification is confirmed. Then turn to the accounts.
That sequencing matters because the two deadlines often cluster. A company with a 31 March year end and a confirmation statement in early spring is managing accounts, corporation tax and identity checks in the same few weeks. Spreading the work removes the risk of discovering a name mismatch in the final week.
The cost of leaving it late
A rejected confirmation statement is not a neutral event. It leaves the filing outstanding, exposes the company to late filing penalties and, if the pattern persists, to the strike-off process. Directors who fail to verify when required risk being recorded as such on the public register, and continuing to act without verification can amount to an offence.
None of this is likely to trouble a well-prepared firm. It is a real risk for the firm that treats identity verification as something to deal with "when the reminder arrives". The reminder may arrive with little time left.
A short checklist to close the loop
Confirm who is in scope and note the exact registered spelling of each name. Check ID validity and consistency. Choose the verification route and, where an agent is needed, book early. Obtain and store every personal code. Diarise the confirmation statement date and work backwards by at least four weeks. Review the public register after filing to confirm that verified status has been recorded correctly.
The register has become more demanding, but the demand is predictable. A director who spends half an hour in the autumn avoids a fortnight of correspondence in the spring.
