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Pension scheme trustees face ID verification deadline


New ID verification rules will also mean pension trustees must prove who they are to Companies House in the UK, experts have warned.

A forthcoming change means millions of people involved with running companies will need to verify their identities to Companies House from November 2025.

But the new rules will also mean pension schemes trustees will also be impacted if the scheme is a limited company in the UK.

Gary Gray, a governance expert with Pinsent Masons, said the change in rules would have an immediate impact on pension trustees.

“In the long run, the new identity verification requirements will improve the veracity of the information available on Companies House about companies and the people that run them,” he said.

“In the short-term, however, pension scheme corporate trustees will need to join all of the other UK companies taking steps to ensure they identify all the relevant individuals subject to verification and then undertaking that verification process.”

Many pension schemes have corporate trustees, with the directors making decisions in relation to the pension scheme. These trustee directors will have to confirm with Companies House their identity once the new rules take effect on 18 November.

New trustee directors will need to verify their identity as part of their appointment, while existing trustees will have a 12-month period to do so – and must verify before the trustee company files its next annual confirmation statement, either directly with Companies House or through an Authorised Corporate Service Provider (ACSP).

Pensions law expert Amie Bain of Pinsent Masons said corporate trustees would need to make sure they were complying with the new rules – and make provision for how it might impact on future trustee director appointments.

“Trustee directors will need to take steps to verify their identity for Companies House purposes over the coming months and should speak to their company secretarial services provider - or whoever normally carries out their company filings to ensure compliance,” she said.

“Appointment processes for new directors will also have to be updated to ensure the new requirements are picked up as part of the onboarding process going forward.” 

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