Introduction

The introduction of Identity Verification requirement (known as IDV) under the Economic Crime and Corporate Transparency Act 2023 marks a significant shift in how Companies House operates. These changes are aimed at tackling fraud, increasing corporate transparency and reforming the role of Companies House. The hope is IDV will improve the accuracy and reliability of individual information held at Companies House, by preventing false identities, such as fictional or deceased individuals being added to the register.

How and When:

A. How do I register?

The sole purpose of IDV is simple: to prove that people are who they say they are.  Once you’ve verified your identity (which you only need to do once), you will receive a personal code, and this code can be linked to your other directorships or persons with significant control (PSC) roles.

There are two different ways to verify, these are:

• directly with Companies House using your Gov.UK One Login account
• via an Authorised Corporate Service Provider (ACSP) (for a charge) – it can be worth checking if your accountant or company secretarial provider is an ACSP

Baxendale Employee Ownership is yet to be an Authorised Corporate Service Provider, but we can help navigate your way through using through the Gov.UK One Login option as follows:

1. Create your own Gov.UK One Login or sign in if you’ve already got one
2. If you need to create an account, you can link your personal or work email to the Gov.UK One Account.
3. UK will then ask you some simple questions to find the best route for you to verify your identity. Once you pick your route, Gov.Uk will provide step by step instructions, the options are as follows:

• Route 1: Download the Gov.UK mobile phone app then follow the steps using your photo ID and confirm your current home address, together with the year you moved in (this is the fastest way
• Route 2: Verify online without using the mobile phone app by entering photo ID details online, answering security questions that are linked to your mobile phone contract, any bank accounts, credit cards or mortgages and then confirm your current home address, together with the year your moved in.
• Route 3: Verify in person via a participating Post Office which will involve receiving a letter or code and then taking your physical photo ID to a participating Post Office. This route may be appealing for those that need additional help or would prefer to avoid a digital route.

B. When do I need to register by?

The ‘when’ is a phased approach over the next 12 months but IDV will be a prerequisite as part of transitioning to employee ownership.  Personal codes will be required when:

• Baxendale EO incorporate a trustee company; and / or
• an individual is appointed to a new directorship of an existing company

This means from Tuesday 18 November 2025, as part of an employee ownership transition timetable, any person(s) agreeing to become a trustee director of a corporate trustee to an Employee Ownership Trust will need to undertake IDV prior to incorporating the corporate trustee. Once we receive the personal codes, we can then proceed with incorporating the corporate trustee.

If you are looking to appoint new directors to any company board within a group, as part of management succession, you will also need to arrange IDV for those individuals. Companies House requires you to notify them within 14 days of a director appointment so the individual will need to ensure they complete their IDV prior to this deadline as you will need the personal code as part of the notification process.

A person that has an existing company directorship will need to also undertake IDV but, as this is a phased approach, the ‘when’ will be determined when your first company confirmation statement is due after Tuesday 18 November 2025. As part of the company confirmation statement you will need to include any of the directors’ personal codes that have yet to be linked to the company. This means you will need to complete the IDV process prior to filing your company confirmation statement.

Where a person has multiple directorships with various organisations, you will need to follow the below process:

1. Check at Companies House when each company’s confirmation statement is due after 18 November 2025.
2. Obtain your personal code prior to the first company confirmation statement that is due and provide your code to the person that files that confirmation statement on your behalf.
3. You do need the personal code for each company confirmation so once you’ve updated the first confirmation statement, we would suggest sending it on to all other persons that might file the remaining confirmation statements due in 2025/2026.

The information provided in this note is a summary as at November 2025; is for general guidance only; and represents our understanding of current law and practice. Specific advice should always be taken on any individual matter when a specific circumstance arises.