UK Directors Face First Prosecutions for Companies House Identity Verification Breaches

Three UK company directors have been convicted and fined in the first prosecutions brought for breaches of the Companies House identity verification requirements introduced under the Economic Crime and Corporate Transparency Act 2023.

The cases were announced on 17 September 2026 and represent an early enforcement action under the new identity verification regime. The directors were fined £166, £307 and £80 respectively following proceedings brought by the Insolvency Service. The cases concerned companies including White (Reading Properties) Limited and J Isogony Apparel Limited.

Identity verification became a legal requirement for UK company directors and people with significant control (PSCs) on 18 November 2025. The requirement was introduced as part of reforms to Companies House under the Economic Crime and Corporate Transparency Act 2023.

Under the regime, directors must verify their identity with Companies House and obtain a personal code. The verification can be completed directly through GOV.UK One Login or through an Authorised Corporate Service Provider (ACSP), such as an authorised accountant, solicitor or company formation agent.

The personal code is an 11-character code issued to an individual following successful identity verification. It is personal to the individual rather than to a company and is used to confirm that the person has completed the required verification. A director with appointments at several companies uses the same personal code for each appointment.

For individuals appointed as directors on or after 18 November 2025, identity verification must be completed as part of the appointment process. When a new company is incorporated, the personal code for each director must be provided as part of the registration filing.

Existing directors were given a transitional period. Their identity verification must be confirmed through the company's next confirmation statement filed on or after 18 November 2025. Directors who hold positions in multiple companies must provide the required confirmation separately for each company.

Separate requirements apply to PSCs. PSCs must verify their identities and provide their personal codes within the applicable 14-day period. Where an individual is both a director and a PSC of the same company, the verification requirements apply separately to each role.

The Companies House enforcement framework states that it is unlawful for a director to act as a director without completing identity verification. A company may also be in breach where one of its directors or an equivalent officer has not completed the required process. PSCs who fail to comply may also commit an offence.

Companies House has a range of enforcement measures available for non-compliance. These include financial penalties imposed on companies or individuals, directions requiring action, annotations to the public register, civil proceedings, criminal prosecution, director disqualification and referrals to other enforcement bodies. Companies and individuals may also face action resulting in the removal of a company from the register in appropriate cases.

The three recent prosecutions therefore concern compliance with the statutory requirements rather than allegations that the directors were involved in money laundering or other financial crime. The cases involved breaches of Companies House obligations, including matters connected with identity verification and corporate filing requirements.

The reforms are intended to improve the reliability of information held on the UK company register by establishing a process through which individuals associated with UK companies can be identified and verified. Companies House has stated that identity verification is intended to provide greater assurance about the identities of people setting up, running, owning and controlling companies.

The verification regime forms part of a wider expansion of Companies House's role under the Economic Crime and Corporate Transparency Act. The legislation has moved Companies House beyond its traditional role as a recipient and publisher of information towards a more active role in checking information and enforcing statutory requirements.

The identity verification process does not replace other customer identification or due diligence requirements. Companies House verification establishes that an individual has completed the registrar's identity-checking process, while regulated financial and professional firms remain subject to their own applicable customer due diligence obligations.

The government has also been implementing the regime in stages for other categories of users. Companies House guidance states that identity verification will subsequently be introduced for people who file documents at Companies House, limited partnerships, corporate directors, corporate members of LLPs and officers of corporate PSCs.

Requirements for people filing documents on behalf of companies have also been subject to changes in the implementation timetable. The requirement for presenters to verify their identity or be registered as an ACSP was originally expected earlier in 2026 but was postponed until November 2026.

The first convictions provide an enforcement precedent for the identity verification requirements. Companies House has stated that it may issue financial penalties at company or individual officer level where directors or PSCs fail to comply, while more serious or persistent cases can be referred for further enforcement action.

The three directors convicted in September 2026 were fined relatively small amounts, but the cases establish that breaches of the identity verification requirements can result in court proceedings and financial penalties. The Companies House regime continues to be implemented across directors, PSCs and other corporate filing roles.

By fLEXI tEAM