First UK ID verification convictions signal step-change in Companies House enforcement role

Gary Gray, a corporate governance expert at Pinsent Masons, was commenting after the Insolvency Service secured its first convictions for identity verification offences in the UK.

The government agency, which is responsible for administering bankruptcies and investigating the affairs of companies in liquidation, secured fines against three directors at City of London Magistrates’ Court on 6 September.

The prosecutions follow the introduction of new, mandatory identity verification requirements last November to help tackle economic crime and prevent misuse of Companies House – the UK companies register.

Companies House is responsible for incorporating, dissolving and registering limited companies in the UK, and historically had only very limited powers to verify the information submitted to the register. However, amid rising concerns over a rise in identity fraud in the UK, on 18 November 2025 it became a legal requirement under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) for directors, and individuals who own or control a company – often referred to as ‘persons with significant control’ (PSCs) – to verify their identities.

Companies House opted to phase in the new requirements over a 12-month transition period to give business owners time to adjust to the new regime. However, existing directors are required to verify their identities during the transition period, with verification commonly being completed in connection with the filing of a confirmation statement.

In these recent prosecutions, a company director was fined for failing to verify her identity for around nine months after the deadline, despite participating in board-level decision-making and signing company accounts. A fine was also issued to another director at the same firm who, although verified himself, was found to have failed to have taken “reasonable steps” to prevent the first director from carrying out her duties, despite knowing she was not verified. Both individuals were also convicted after their firm failed to file a confirmation statement on time.

Separately, a director at a different firm was also fined for signing and delivering company accounts while unverified, and for her failure to file a confirmation statement within the requisite time period.

The fines come less than two months before the end of the identity verification transition period and highlight the need for firms to ensure the identity verification of individual directors is up to date.

Gray said the looming November deadline should serve as a wake-up call for company secretaries to ensure their filings are accurate and, where necessary, challenge directors on inconsistencies and discrepancies before information is submitted to Companies House. “These convictions mark a distinctive shift from Companies House as a register to a quasi-regulator – it should no longer be treated as a passive filing destination,” he added. “Good company secretarial practice now requires stronger assurance over the information entering, and remaining on, the register.”

These prosecutions are the latest example of the register’s increasingly expansive powers. In 2024, the register published its first strategic intelligence assessment aimed at addressing “the abuse of UK corporate structures that facilitates economic crime”. It said that the new statutory powers granted under ECCTA had “fundamentally” changed its role, giving it more clear objectives and wide-ranging powers to reject, remove or rectify company register information as well as a greater capacity to analyse and share data and information with public and private sector entities, including law enforcement bodies.

Adam Kohl, an expert in company secretarial services, said the prosecutions also underscore the importance of businesses maintaining up-to-date record-keeping, tracking onboarding and verification requirements linked to new directors and having appropriate processes in place to handle Companies House queries promptly. "For many organisations, the challenge is no longer simply understanding the rules, but implementing the processes needed to comply with them consistently,” he said. “Companies should review their internal governance frameworks to ensure director appointments, identity verification requirements and statutory filing obligations are monitored and managed proactively."

Authorised corporate service providers (ACSPs), which are Companies House authorised agents, are already required to verify their identity as part of the authorised agent regime. Kohl said directors based overseas are increasingly calling on ACSPs to assist with identity verification and compliance with the new Companies House requirements.