On 18 November 2025, identity verification at Companies House moved from voluntary to mandatory. If you accept a director appointment or become a Person with Significant Control on or after that date, the company cannot lawfully record the appointment on the public register until you have completed identity verification under the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023) and obtained a Companies House personal code. If you were already a director or PSC on 17 November 2025, nothing changed for you instantly: you have a twelve-month transition window, during which the company's next confirmation statement must carry verified personal codes for every in-scope individual, ending around November 2026.

This page sets out the calendar mechanic in plain language: what changed on 18 November 2025 compared with the day before, who is in scope from day one and who is on a runway, what the transition window actually means for existing directors and PSCs, and what you should do this week. For the deep operational walkthrough (One Login versus ACSP route choice, multi-SPV mechanics, per-company filing cadence, sanctions detail) see our ECCTA identity verification operational page. For a definitional explainer of the regime, see our complete guide to identity verification in the UK.

What Changed on 18 November 2025?

On 17 November 2025, you could be appointed a director of a UK company at 11:00 in the morning, have the appointment filed at Companies House at 14:00 in the afternoon, and have the entry on the public register by the close of business. No identity verification, no personal code, no problem. Voluntary verification had been open since 8 April 2025, but the choice to do it was yours.

On 18 November 2025, the same sequence breaks. The appointment filing now requires the appointee's Companies House personal code, issued under ECCTA s.68. If the code is missing, the appointment cannot lawfully be recorded. The company has not legally appointed a director until the verification is complete and the code is quoted on the filing.

For the existing director or PSC, the same date opened a twelve-month transition window. On 18 November 2025, every existing role became time-limited under the new regime: verification is required by the next confirmation statement filed within the window. The window closes around November 2026; by then, every director and PSC of every UK company should be verified, and any unverified individual remaining in role becomes individually exposed to the criminal-offence and civil-penalty stack that ECCTA created.

The legal architecture sits in ECCTA 2023 Part 1, the Identity-verification crossheading. The operative sections, all verifiable verbatim at legislation.gov.uk, are s.64 (Identity verification of persons with significant control), s.65 (Procedure etc for verifying identity), s.66 (Authorisation of corporate service providers), s.67 (Exemption from identity verification: national security grounds), s.68 (Allocation of unique identifiers), and s.69 (Identity verification: material unavailable for public inspection). The director-side provisions sit in the Directors crossheading immediately before this group. Together they amend the Companies Act 2006 to insert a new verification regime as a precondition to lawful directorship and PSC roles.

Does the Regime Apply to Me From Today?

There is a clean three-way split, and the question to ask first is which slot you sit in.

Newly appointed director or PSC (appointed on or after 18 November 2025). Yes, the regime applies from day one. You must verify your identity before the appointment can be recorded on the public register. The practical effect is that verification has to be part of the appointment workflow, not an afterthought. If you have agreed to be appointed but have not yet been filed at Companies House, sequence the verification first, the filing second.

Existing director or PSC (in office on 17 November 2025). Yes, the regime applies, but on a runway. You have until the company's next confirmation statement falling within the twelve-month transition window (18 November 2025 to around November 2026) to verify your identity. Each company has its own confirmation statement date; your deadline is set by that date. If you hold roles in several companies with different confirmation statement dates, the earliest one fixes your operational deadline (because all your companies share the same single personal code, you have nothing to gain by serialising the verification).

Not a director or PSC at all. The regime does not reach you until you accept a new role. Family-investment-company shareholder children without PSC status, BTL silent investors who hold below the PSC threshold, and the general public are all outside the scope of mandatory verification. Note that the PSC threshold (broadly, more than twenty-five per cent of shares or voting rights, or other significant influence as set out in Companies Act 2006 Sch 1A) is sometimes crossed by accident through share-class engineering or trust arrangements; if you are uncertain whether you are a PSC, that is a question worth resolving before the company's next confirmation statement, regardless of the verification timeline.

The classification turns on the appointment date, not on the verification status. Anyone in role before 18 November 2025 is existing, even if they were appointed only one week earlier. Anyone in role from 18 November 2025 onwards is new, even if the appointing company is decades old.

What Does the Twelve-Month Transition Window Actually Mean?

Each UK company has a confirmation statement filing cycle, annual, anchored either to the incorporation anniversary or to twelve months from the previous filing. The confirmation statement is the company's annual certification that the public-register data is correct.

Within the twelve-month window from 18 November 2025 to around November 2026, the next confirmation statement filed for the company must carry verified personal codes for every in-scope director and PSC. Companies House will refuse a confirmation statement filing that is missing required codes; the company is then in late-filing territory under Companies Act 2006 ss.853A to 853L, with the criminal-offence and civil-penalty consequences attached.

The practical operational point is timing within the window. The verification process is fast for the typical biometric-passport holder (ten to thirty minutes via GOV.UK One Login, faster still via an ACSP that already holds your AML KYC), but the document-check queues and the ACSP capacity tighten near the closing deadline. The same operational pattern was visible during the early voluntary phase between April and November 2025, when most directors who had volunteered waited until the last fortnight and ran into delays. Booking the verification in December 2025 or January 2026 is the operational hygiene point.

One transition-window subtlety often missed: it is the confirmation statement filing date, not the year-end date, that matters. If your company's confirmation statement is due on (say) 15 March 2026, that is your binding deadline regardless of the company's financial year-end. The free Find and update company information service at the Companies House website shows the next confirmation statement date for every UK company; check it now if you have not done so already.

How New Appointments Work From 18 November 2025

For a newly appointed director or PSC, the practical sequence is now reversed compared with pre-18 November 2025 practice.

Pre-18 November 2025, the company filed the appointment first; the appointee then maintained the role at the discretion of the appointing organs. Post-18 November 2025, the prospective director or PSC must verify first, obtain a Companies House personal code under ECCTA s.68, and then the company files the appointment quoting the code. Companies House rejects the filing if the code is missing.

Worked example: Mr Patel agrees on Monday morning to be appointed director of a new buy-to-let SPV that is being incorporated to acquire a freehold flat. The acquisition completion is on Friday. The verification has to happen at the start of the week, not the end: Mr Patel downloads the GOV.UK One Login app on Monday afternoon, scans his biometric passport, completes the liveness check, receives his personal code by Monday evening or Tuesday morning. The company can then file the AP01 on Wednesday and the appointment is recorded in time for the Friday completion.

This sequencing point matters operationally because property transactions usually run on tight deadlines and the appointment chain (incorporation, appointment, opening bank account, completing acquisition) is now critically dependent on the verification being done up-front. Treat verification as part of the conveyancing critical path, not an afterthought.

The Multi-SPV Reveal: One Verification Covers Everything

For multi-SPV landlord portfolios this is the single most operationally useful fact about the new regime.

Verification under ECCTA s.65 is per natural person, not per company. The Companies House personal code allocated under s.68 is per natural person, not per company. The same personal code is then quoted at every confirmation statement and every appointment filing for every UK company in which the natural person holds a director or PSC role.

Worked example: Mr Singh is director and one-hundred-per-cent PSC of five buy-to-let SPVs, each holding two or three flats. Confirmation statement filing dates are spread across the year (March, May, July, September, November). Mr Singh completes One Login verification on 20 November 2025 in twenty-two minutes total, receives one personal code under ECCTA s.68. That same code is then quoted on five separate confirmation statements over the following twelve months: March 2026 for Singh BTL 1, May 2026 for Singh BTL 2, July 2026 for Singh BTL 3, September 2026 for Singh BTL 4, November 2026 for Singh BTL 5. Five companies, one verification, one code.

The fee economics follow the same pattern. The One Login route is free, so the marginal cost of multi-SPV coverage is zero. The ACSP route typically charges a fee per natural person in the £20 to £100 range (verify the precise figure with the firm); the fee is amortised across every directorship and PSC role held, so a family group of (say) four natural persons across twenty SPVs sees the ACSP cost of four verifications, not twenty.

This is why, for portfolio families, the ACSP route via your accountant or company-secretarial firm often makes more operational sense than five or ten separate One Login sessions, even though One Login is free per individual. The firm batches the family verifications, slots the personal codes into its confirmation-statement workflow, and the entire portfolio is in compliance by Q1 of the transition window.

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The Overseas Director Angle

The 18 November 2025 commencement and the twelve-month transition window apply regardless of where the director or PSC is resident. A UK-citizen director living in Dubai, a US-citizen PSC of a UK property company, an EU-resident family member with a PSC interest through a discretionary trust: all are within the regime on identical terms.

The operational route is usually GOV.UK One Login via the app, with a biometric passport. Most modern passports issued by countries that have adopted biometric chip standards work; the One Login document list is published on the GOV.UK Verify your identity guidance page and is worth checking against the specific passport before booking.

Where the home-country passport is not supported, or where the director prefers an adviser-managed route, an Authorised Corporate Service Provider can verify remotely via video call and document review. The ACSP route is particularly common for US-based directors of UK property companies, where the existing accountant relationship plus the US compliance overlay (FBAR, Form 5471, Form 8938) make a single integrated handler the easier operational choice. Our dedicated US-based directors page covers the US-specific operational angle in detail (the cluster expands across the broader ECCTA reform map).

What Happens If I Miss the Deadline?

Continuing to act as a director or PSC of a UK company without being verified by the applicable deadline is a criminal offence under the ECCTA 2023 framework. The early-rollout enforcement pattern is still building, but the legal architecture is in place: fines for individuals, escalating penalties for persistence, and cumulative non-compliance feeding into disqualification proceedings under the Company Directors Disqualification Act 1986. The Insolvency Service is the enforcement body for disqualification.

The company itself is exposed alongside the individual. Companies House will refuse a confirmation statement filing that is missing required personal codes for any in-scope director or PSC. The company is then in late-filing territory under Companies Act 2006 ss.853A to 853L (as amended by ECCTA), with criminal offences for failure to file. The civil financial-penalty regime allows penalties for relevant filing failures.

The compound effect is what makes the cost of missing the deadline disproportionate to the cost of completing the verification. The company cannot file its confirmation statement; the late filing is a search-visible red flag to lenders, tenants, insurers, and counterparties; cumulative late filings can move the company towards strike-off; the individual carries the criminal-offence exposure; and the disqualification track sits in the background as the long-tail consequence. The verification takes ten to thirty minutes; the consequences of skipping it can last years.

What Else Is in the ECCTA Reform Pipeline?

Identity verification is one of several parallel Companies House reforms introduced by ECCTA 2023 Part 1. The wider reform map (each covered in sibling pages or our broader cluster) includes the Registrar's new statutory objectives at ECCTA s.1, the registered email address requirement for every UK company (in force from 4 March 2024), the appropriate-address rule for the registered office (no PO-box-only addresses), the lawful purposes statement on every confirmation statement (in force from 5 March 2024), the abolition of locally-held PSC and director registers (consolidating everything at the central Companies House register), the Authorised Corporate Service Provider framework under ECCTA s.66, and substantial tightening of the Register of Overseas Entities framework introduced by the Economic Crime (Transparency and Enforcement) Act 2022.

A later phase, expected no earlier than November 2026, will extend identity verification to people who file at Companies House (agents, accountants, formation agents) and to corporate-officer scenarios. The campaign page tracks the published commencement dates as they are confirmed; the conditional framing is deliberate because the operative state of the rollout moves.

For the umbrella view, see our companies-house-reforms page; for the navigation-roadmap view, see companies-house-reforms-navigating-the-new-landscape; for the policy-shift interpretation, see companies-house-tightens-id-rules-what-does-it-mean; for the confirmation-statement pillar, see confirmation-statements and the 2024-onwards changes operational deep.

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