Companies House Identity Verification: First Prosecutions Highlight Director Liability

At a Glance

• The Insolvency Service has secured its first convictions under the new Companies House identity verification regime, with three company directors fined in September 2026.
• These cases show that liability is not limited to the unverified director. The company and its officers may also be found guilty of an offence, including co-directors who have duly verified their own identities.
• With the 12-month transition period for existing directors and PSCs drawing to a close, companies should now confirm that every director and PSC has verified.

The convictions, handed down on 16 September 2026, make clear that the new rules are not optional. In this alert, we outline what the regime requires, who may be liable, and the steps companies should be taking now to ensure compliance.

The Requirement

The Economic Crime and Corporate Transparency Act 2023 amended the Companies Act 2006 to introduce identity verification requirements for directors and people with significant control (PSCs). These came into force on 18 November 2025, and since then newly appointed directors have had to verify their identity before they can act.

Existing directors and PSCs were given a 12-month transition period, starting on the same date, with the precise deadline for their verification depending on their role:

• Existing directors must verify their identity and provide their personal code with the company's next confirmation statement.
• Existing PSCs who are also directors of the same company must provide their code separately as a PSC, within the 14 days following the confirmation statement date.
• Existing PSCs who are not directors must provide their code within the first 14 days of their birth month.

As the regime approaches its first anniversary, most companies will have already filed, or will shortly file, the confirmation statement that sets their directors' deadlines. Note that these verification obligations also apply to members of UK LLPs and directors of overseas companies that have a UK establishment. 

Who Is Liable?

It is an offence for an individual to act as a director unless their identity has been verified. If an unverified individual does act, the offence is committed by that individual and also by the company and its other officers. Directors and officers may therefore be liable for another’s failure, even if they have duly verified their own identity.

The regime does not generally invalidate the acts of an unverified director, so board decisions and documents are not automatically ineffective. The risk lies in criminal liability for the individuals and the company concerned.

The First Convictions

Jill White, a director of White (Reading Properties) Limited, participated in board decisions and signed accounts while unverified, only completing verification around nine months after the deadline. Her co-director, Marc Dillon, had verified his identity but was convicted for failing to take reasonable steps to prevent her from acting while unverified, despite knowing of the requirement.

Separately, Modinat Banjo, a director of J Isogony Apparel Limited, signed and delivered accounts before verifying her identity. All three directors were also convicted after their companies failed to file confirmation statements on time.

The fines themselves were relatively modest, ranging from £80 to £307 plus costs and surcharges. What matters more is that Companies House and the Insolvency Service have shown they are willing to prosecute directors who do not comply. As the Insolvency Service put it, "There is no option to opt out."

How to Verify

Individuals can verify their identity for free online through GOV.UK One Login, using accepted photo ID such as a biometric passport or UK photo driving licence, together with the individual's current address and the year they moved in.

UK residents without suitable photo ID may be able to verify using bank or building society details and a National Insurance number, or in person at a post office. Verification can also be carried out through an authorised corporate service provider (ACSP) who is registered with Companies House and whose name appears on the UK government’s public list of ACSPs.

Next Steps for Companies

UK companies should now be:

• Confirming the verification status of every director and PSC.
• Checking confirmation statement dates to be aware of each individual's deadline and diarising any that are still outstanding.
• Confirming that fellow directors have verified, since directors and officers may be liable if they fail to take reasonable steps to prevent an unverified director from acting.
• Updating onboarding procedures so that new directors verify their identity before they act.
• Responding promptly to any correspondence from Companies House, given that the recent prosecutions followed repeated attempts to secure compliance.
• Considering whether to use an ACSP to manage verification across a group, or for individuals who cannot verify online.