What’s happening with Companies House identity verification?

Published: 5 August 2024 3:32 pm Author: Oliver Stanley

At Kudocs, we simplify company management for business owners and professional advisers.

As part of this, we keep abreast of important Companies House regulatory changes to help our customers manage company registers in compliance with current law.

Companies House is continuing to prepare for the launch of the new Identity Verification (IDV) requirements as set out in ECCTA 2023. In a recent catch-up with Companies House, we’ve learnt a few more useful bits of information about the intended rollout of this significant change to how entities and stakeholders interact with Companies House.

Disclaimer: this post is based on recent informal discussions with Companies House, who was happy for us to share the details of our conversation. All of the information is indicative only at this stage as Companies House is still clarifying the details of how and when implementation will take place. For more specific information, please contact Kudocs directly (we will share anything we can) or seek professional advice.

Key Takeaways

In order to comply with the IDV requirements, certain entity stakeholders (e.g. company directors, PSCs, members and partners of LLPs) will need to (i) obtain a unique personal code from Companies House and (ii) include that code as part of certain filings. This will enable Companies House to verify identities and connect new and existing stakeholders in Companies House with their approved identity.
No earlier than February 2025, Companies House will allow third parties (i.e. professional advisers) to register as ACSPs, so that they can begin completing IDV for their clients and clients’ stakeholders.
No earlier than March 2025, Companies House will activate OneLogin as the method for individuals to complete IDV directly.
No earlier than September 2025, the inclusion of the personal code will begin to be mandatory for new incorporations, confirmation statements, and other filings.

What is the IDV requirement?

Companies House is introducing a new identity verification process to help prevent economic crimes. Anyone setting up, running, owning or controlling a legal entity in the UK will need to verify their identity to prove they are who they claim to be.

This means that for new entities, all directors, LLP members and people with significant control (PSCs) will need to complete identity verification.

For existing entities, all directors, LLP members and PSCs will have a transition period to verify their identity with Companies House.

For more information see Companies House.

IDV Process for Individuals

Individuals can complete IDV through OneLogin‘s verification process. This is likely to require the submission of approved documents (e.g. utility bill) and biometric information (e.g. a photo). Once verified, Companies House will generate and send a personal code directly to the individual by email (the individual will have to provide an email address as part of the verification process).

IDV Process for ACSPs

Professional advisers will be able to complete IDV using their existing regulated KYC and AML procedures. Therefore if a professional adviser has already completed identity verification of an individual, Companies House will accept the professional adviser’s word – they will not need to red0 verification and nor will the individual be required to register via OneLogin.

In order to do this for clients, the professional adviser will need to register as Authorised Corporate Service Providers (ACSPs) with Companies House.

After verifying an individual in accordance with their own regulated standards, the ACSP will submit the necessary confirmation through a dedicated portal at Companies House to register that individual as verified. Companies House will generate and send a personal code directly to the individual by email (the ACSP will have to provide an email address as part of the verification process). Currently Companies House plans to require ACSPs to register each individual one at a time, but we are exploring if there is a way we can help customers with a bulk registration process.

Companies House will only allow one email address to be used by one individual. This is important to note, for ACSPs, as even if they register their clients for IDV and the personal code, Companies House will send that code to the individual directly. So the ACSP will need to get their clients to forward that code to them for future filings.

IDV Timeline

Companies House is aiming to enable third party advisers to register as ACSPs from no earlier than February 2025. Once registered, ACSPs will be able to start completing IDV for their clients in order to obtain the personal code.

Companies House is aiming to enable individuals to complete IDV via OneLogin no earlier than March 2025.

Companies House is aiming to make IDV compulsory no earlier than September 2025. Once IDV is compulsory, the inclusion of the personal code as part of the submission for various filings (including new incorporations and officer appointments) will be mandatory).

How will Companies House obtain personal codes for existing stakeholders & entities?

If you incorporate a new company or appoint a new director, etc. after IDV implementation, you will have to provide the personal code.

But what about existing entities where there is no change needed? Companies House are planning to require the personal code for all relevant stakeholders to be submitted in the first confirmation statement after the requirement goes live.

Therefore IDV will need to be completed for all stakeholders in the first ~12 months after go live.

This will allow Companies House to have, within approx 12 months, all individuals uniquely identified and it will allow Companies House to use the personal code to de-duplicate the records.

At Kudocs, we prioritise your peace of mind by ensuring full compliance with current Companies House regulations. Our seamless solutions make it simple for you to stay compliant and focus on running your business.

Discover how we can support your company with:

Managing company registers

Handling share issues, transfers, and capital changes

Facilitating board and shareholder decision making

Providing automatic Companies House e-filings

Managing cap tables and options

Offering secure document storage

If you’re not already a Kudocs customer, book a demo here to learn more about how we can streamline your company’s or clients’ administration.