From 18 November 2025, Companies House introduced mandatory identity verification for company directors and People with Significant Control (PSCs). This forms part of the Economic Crime and Corporate Transparency Act (ECCTA) and aims to improve transparency while reducing fraud.
However, while the intention remains positive, the rollout has created uncertainty. Some PSCs are now receiving unexpected compliance letters, even though they believe they already met the identity verification requirements.
Overdue Identity Verification Letters for PSCs
During late 2025 and early 2026, an increasing number of PSCs have been receiving letters from Companies House. These letters state that an identity verification statement for a PSC role is overdue and cannot be extended.
Typically, the letters include:
- Confirmation that the legal deadline has passed
- Instructions to submit an identity verification statement or make a formal representation
- A fixed response deadline
- A warning about potential prosecution or financial penalties
Many recipients already completed identity verification earlier in the rollout. In some cases, they verified as directors and believed this also covered their PSC role.
An Issue in the System
Current guidance suggests that identity verification applies to the individual rather than each separate role. Where a person acts as both director and PSC, the system should recognise their verified status.
However, reports point to a mismatch between director verification records and PSC records. In simple terms,
- The initial identity check confirms the individual
- The PSC register does not always link to the verified director record
- Companies House then issues an automated overdue PSC notice
In many cases, the issue does not appear to result from user error. Instead, it suggests a technical or procedural gap during the early stages of system implementation.
A Potential Verification Solution for PSCs
If you receive an overdue PSC identity verification letter, do not ignore it. You will need to do the following yourself:
- Log into Companies House and review your identity verification status
- Confirm whether you already hold a valid personal code
- Check whether your PSC role shows as verified separately
- Submit the required PSC statement if the system allows
- Keep records of prior verification confirmations
Where the system does not allow submission, you may need to make a formal representation. The letter should explain how to do this and what information to include. Companies House treats identity verification as a legal requirement. Even where the issue appears system-led, penalties may still apply if you take no action.
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