Who Signs the Register: A Practical Identity-Verification Routine for UK Firms
Photo: UK company directors reviewing identity documents in a professional office meeting, via imaging.broadway.com
Most firms have a mental model of Companies House that is now out of date. For years the register behaved like a postbox: documents went in, an acknowledgement came out, and verification of the people behind a company was somebody else's problem. That assumption no longer holds. Identity verification under the Economic Crime and Corporate Transparency Act has shifted the register towards a checked record, and it puts a personal obligation on directors, people with significant control, and the members of limited liability partnerships.
The timing matters. Verification opened on 18 November 2025, and the twelve-month transition period for existing directors runs out on 18 November 2026. After that point, a director who has not verified cannot lawfully be appointed, and companies face a straightforward practical problem: filings stall, penalties follow, and the register records the gap publicly. Firms that advise owner-managed businesses should treat the next fortnight as a deadline and the year after it as a habit.
What the obligation actually covers
Verification is personal, not corporate. An individual proves their identity once, either directly through a GOV.UK One Login account or through an Authorised Corporate Service Provider — typically an accountancy or legal practice that has registered with Companies House and is supervised under the money laundering regulations. Once verified, a confirmation is attached to the individual's record, and it follows them across every company they direct or control.
The categories are wider than many clients expect. Directors of all companies and LLP designated members are in scope. So are people with significant control, and the equivalent of a PSC for LLPs. Where a corporate entity sits in the ownership chain, verification obligations travel to the individuals within that chain. A holding company based overseas does not remove the requirement; it usually makes the evidence trail harder to assemble.
Where verification meets the annual cycle
For existing directors who have not yet verified, the natural trigger is the confirmation statement. Companies House has linked the two so that verifying becomes part of confirming the register is accurate — which, in substance, it now is. This is an elegant piece of policy design and an awkward piece of operational reality, because confirmation statements cluster in the same months for whole sectors and most firms handle them reactively.
That is the trap. If a client's statement is due in three weeks and the director has no verified identity, the firm is not dealing with a filing — it is dealing with a queue. OneLogin registrations, document checks, discrepancies in name spellings across the register, a passport that expired, a director resident abroad whose evidence is not accepted: any of these can consume the remaining time.
The onboarding change most firms have not made
Client onboarding is where verification should be caught, and in many practices it is still where the old assumptions live. Engagement letters, anti-money-laundering checks and Companies House verification are frequently treated as three separate conversations run by three separate people. Consolidating them is not bureaucratic tidiness; it shortens the distance between a question a client will answer honestly and a filing that will be accepted.
There is also a presentational point. Clients will ask whether the firm is now acting as a gatekeeper to the register. The honest answer is that verification is a check on identity, not an endorsement of the person's conduct or of the company's affairs, and that a firm acting as an ACSP is carrying out a statutory function under supervision — not signing off on the business. Language matters here, because a client who believes the firm has guaranteed them a clean register will be disappointed later.
A four-part readiness check
One — build the list before the deadline builds it for you. Run every client company against the register and identify, by company, which directors and PSCs have a verified status and which do not. Record the confirmation statement date beside each name. This is an afternoon of work that prevents a season of it.
Two — fix the identity data first. Verification fails on mismatches more often than on anything else: middle names omitted, maiden names retained, dates transposed. Compare the register entry against the passport before anyone starts a check.
Three — agree who does the check and in what capacity. If the firm acts as an ACSP, confirm which supervised individual performs the verification, whether the client understands the fee and the scope, and where the evidence is retained. If the firm does not act as an ACSP, say so early and point the client towards direct verification rather than discovering the gap at the point of filing.
Four — set a stopgap rule. No confirmation statement leaves the practice without a verified-status confirmation on file, and any exception is recorded in writing with the reason and the client's acknowledgement. A short written rule beats a long memory.
Communicating without alarming
Most owner-managers will not have read the guidance. The message that works is short and specific: what is required, who it applies to, what the client needs to hand, how long it takes, and what happens if it is missed. Avoid framing it as an investigation. It is an administrative condition of holding office, and the tone should match the certainty of that statement.
For larger client portfolios, staggered correspondence is worth the effort. Sending every client the same letter in the same week invites a volume of replies that no team can service, and the resulting backlog is indistinguishable to the client from delay.
What to do next
Two practical steps. First, identify any client whose confirmation statement falls before 18 November 2026 and whose directors remain unverified; those are the acute cases. Second, put verification on the standard new-client checklist and on the annual review agenda so that the obligation is absorbed into existing routines rather than bolted on.
The register is becoming a record of verified facts. Firms that build the check into their ordinary processes will barely notice the shift. Firms that wait for a rejected filing will notice it once, sharply, and in front of the client.
