ID Verification checks for directors
Written by Ray Coman
From about August 2025, Companies House will be introducing a new ID check requirement for all company directors. The requirement arises from The Economic Crime and Corporate Transparency Act 2023 (ECCTA), which was introduced in response to a toughening sanctions environment.
Consequences of non compliance
Director requirement
Each director of a UK company will be required by Companies House to carry out their own Anti-Money Laundering (AML) check. Effectively, the Companies House platform will identify all UK directors via a real-time face recognition check.
Gov.uk One Login
Typically, the most efficient method for verification by a director is carried out using the gov.uk mobile phone app. The App is linked to a gov.uk login which is set up separately, usually via a desktop device. The App will scan biometric ID. For instance, holding the outside of a passport to a smart phone will obtain biometric data. The App will match the picture on the photo ID to the facial image on the camera of the smart device using face recognition. Once the director’s identity has been successfully proven, he or she will be able to start using the gov.uk One Login services.
Authorised agent requirement
Coman&Co is registered as an authorised Corporate Service Provider (ASPC.) An ASPC is also known as a Companies House authorised agent. Our UK Anti-Money Laundering (AML) supervisory body is the ACCA.
Accountants have been required to obtain photo ID and proof of address for all new clients since the introduction The Money Laundering Regulations 2007.
Under the regulation enforced from 2025, our agency will be required to verify the identity of directors on Companies house prior to being able to file documents with the registrar on behalf of companies. For every director, it will be a requirement to run an Anti-Money Laundering check. In practice, this is carried out via our in-house software, using identity document validation technology.
We are required to confirm that the photo ID obtained for all directors represents a true likeness of the director. The director’s details are then run through our software checking: name, and ID documents, against a centralised database.
The centralised database amalgamates various databases around the world for Politically Exposed Persons (PEPs) and Criminal Records.
Once Coman&Co has confirmed the director’s identity, we login to the ACSP portal and tell Companies House that we have completed the check on the individual director. We need to enter the director's email address associated with the check. In response, Companies House will email a code to the director concerned. The email address has to be unique to each director. The corresponding code is therefore unique and lifelong and can be thought of in that sense in the same way as a national insurance number.
The code will transcend companies. Verified directors will not need to be verified again if they wish to be appointed to another company.
In summary, the director provides their unique code to his or her accountant, which will be required to file with Companies House.
The public register will show that Coman&Co carried out the check (our supervisory body, which is the ACCA) and the date on which the AML checks were carried out.
Coman &Co will retain name, email address, home address and date of birth for all directors who are also clients. We are required to retain the ID check information for seven years.
Consequences of non compliance
Any director that does not carry out ID verification with both the registrar and with the authorised agent, will not obtain a code. Without the code, a company would not be able to file required annual documents- such as the confirmation statement-. Failure to file documents will result in compulsory strike off by Companies house. A company that has been struck off does not exist and this usually means its bank account is automatically frozen.
Summary
In addition to the checks that the directors carry out for AML purposes, the authorised Corporate Service Provider, in our case Coman&Co, is required to carry out a corresponding ID check requirement. This will place extra administrative burden on directors; and some could be dissuaded by privacy concerns. On the other hand, the tighter requirements should act to improve the credibility of directors putting forward heir business via a UK registered company.
