Identity verification at Companies House moved from a voluntary scheme to a legal requirement on 18 November 2025 for newly appointed directors and persons with significant control (PSCs). Existing directors and PSCs in place before that date sit in a 12-month transition window, with their verification deadline anchored to the next confirmation statement their company files within or after the window. A separate later phase, scheduled no earlier than November 2026, brings people who file at Companies House on behalf of others (filers) and corporate-officer scenarios into the regime. This page is operational, not theoretical: it maps the obligation against the practical realities of a multi-SPV buy-to-let limited company portfolio and explains the route choice, the per-company filing cadence, and the consequences of acting in an unverified capacity.

Verification timestamp for the operative state in this page: 25 May 2026, checked against changestoukcompanylaw.campaign.gov.uk/identity-verification and the Companies House blog. The page should be re-checked against the campaign page at the point of any filing because the rollout sits mid-transition. The position recorded here may have moved by the next confirmation-statement window for any given company.

Why this regime exists and what it is built to do

The Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023 c. 56) is the largest reform of Companies House since the Companies Act 2006 itself. Part 1 of the Act, organised in twenty-three sections grouped under italic crossheadings (no Chapter structure), rebuilds the Companies House role from a passive registry that accepts what filers send it into an active gatekeeper that verifies identity, refuses non-compliant filings and intervenes on suspect registrations.

The identity-verification block of Part 1 sits under the Identity verification crossheading at sections 64 to 69, with mechanical insertion of director-side provisions also taking place through the Directors crossheading at sections 40 to 45 (sections that operate by inserting new provisions into the Companies Act 2006 itself; the verbatim CA 2006 inserted-section numbers should be quoted from legislation.gov.uk at the point of any formal advice). The verbatim section headings under the Identity verification crossheading are:

  • Section 64: "Identity verification of persons with significant control"
  • Section 65: "Procedure etc for verifying identity"
  • Section 66: "Authorisation of corporate service providers"
  • Section 67: "Exemption from identity verification: national security grounds"
  • Section 68: "Allocation of unique identifiers"
  • Section 69: "Identity verification: material unavailable for public inspection"

The architecture is deliberately split: the Identity verification crossheading carries the PSC-side and procedural backbone, while the director-side mechanics flow through the Directors crossheading sections 40 to 45 that amend the Companies Act 2006 director-appointment regime. Practical implementation is unified through a single Companies House personal code per natural person that links the verified identity to whatever roles that person holds.

The four operational realities a landlord-LtdCo portfolio needs to absorb

One natural person, one verification, one code

For a landlord who is director of multiple SPVs and PSC of those same SPVs, the verification is a single natural-person event, not a company-by-company exercise. The Companies House campaign page explains that once an individual has verified via GOV.UK One Login or through an Authorised Corporate Service Provider (ACSP), Companies House issues a unique personal code linked to that verified identity. The code is then quoted in filings for every company in which that person is recorded as a director or PSC.

This bends the operational headcount in the right direction. A landlord with five property SPVs is one natural person in the verification queue, not five. A husband-and-wife structure across the same five SPVs is two natural persons. A typical buy-to-let portfolio with a single founder-director who is also sole PSC is one verification event. A common Family Investment Company arrangement with founder-parents and adult-child shareholders adds the adult-child PSCs above the 25% threshold to the headcount but does not multiply the per-person work.

The code lives with the person; the filing lives with the company

What the code does NOT do is auto-populate Companies House filings across the portfolio. The personal code is provided per filing, per company. For an active multi-SPV landlord, this means each SPV's next confirmation statement (or earlier appointment filing) is the operational moment where the code is supplied. Most accountants and company-secretarial agents batch this work, capturing the personal code once in their client file and inserting it as needed across the confirmation-statement run for the year.

The per-company filing cadence matters when planning the verification timing. A landlord whose five SPVs have confirmation dates scattered across the year sees the personal code threaded into each filing window in turn; a landlord whose SPVs all share a confirmation date (because they were incorporated in a single founding window) sees one concentrated filing week each year where the code is quoted five times in quick succession.

The route choice: GOV.UK One Login or ACSP

The two routes are alternatives, not stages. Either route produces the same outcome (a verified identity and a personal code), and the choice is largely a function of how the landlord prefers to interact with the system.

  • GOV.UK One Login. Free, self-service, typically five to fifteen minutes per person. Requires a smartphone with a working camera and a biometric document (passport or photo driving licence). Most landlords who already file Self Assessment online have an active GOV.UK One Login account and can complete the additional Companies House verification step from the same login. The route is documented on gov.uk under "verify your identity for Companies House".
  • Authorised Corporate Service Provider (ACSP). The accountant or company-secretarial firm completes identity checks using the documents it already holds under its anti-money-laundering file, then submits the verification to Companies House on the client's behalf. The ACSP must be a UK firm that is supervised for AML purposes under the Money Laundering Regulations 2017 and that has separately registered with Companies House as an ACSP. The ACSP register is searchable on the Companies House service. The route suits landlords who do not have an active GOV.UK One Login account, who prefer their accountant to handle Companies House interactions, or where the documents need to be checked in person.

The ACSP route involves a fee charged by the firm. The GOV.UK One Login route is free at the point of use. For a single-director SPV where the founder has a UK passport and an active GOV.UK One Login account from personal tax filings, the One Login route is typically faster and free. For a multi-shareholder Family Investment Company where the documents need careful chain-of-custody (overseas-resident PSCs, complex share structures), the ACSP route often wins on operational simplicity even with the fee attached.

Verification before filing, not before the year ends

The trigger for verification is not the calendar year. It is the next confirmation statement (or earlier appointment-related filing) for the company in question. A director whose company has a confirmation date in October will, in the existing-cohort transition window, have until that October to verify (with a 14-day filing window after the confirmation date). A director whose company has a confirmation date in February faces a tighter window.

The implication is portfolio-level planning. A landlord with five SPVs whose confirmation dates are scattered between January and December has to think about the WHOLE portfolio when planning verification timing: verifying in late October for the October-confirming SPV means the code is available when the next SPV (December confirming) also needs it, then the January SPV, then the March SPV. Verifying ad hoc, SPV by SPV, in the week before each filing leads to predictable last-minute scrambles. The discipline that works is verify once, early in the calendar year, and use the code across every confirmation that follows.

Worked operational scenario: Tom and Priya, three-SPV BTL portfolio in West Yorkshire

An anonymised worked example helps anchor the mechanics against actual portfolio shape. Tom and Priya hold six buy-to-let properties via three SPVs:

  • Trent Holdings Ltd, two Leeds flats. Tom and Priya both directors. Shareholding 60% Tom and 40% Priya, so both above the 25% PSC threshold.
  • Calder Properties Ltd, three Bradford terraces. Tom sole director and 100% PSC.
  • Aire Investments Ltd, one Halifax HMO. Tom and Priya both directors. Shareholding 50% each, so both PSCs.

The natural-person headcount for verification is two: Tom and Priya. Not five (one per company) and not six (one per role per company).

Route choice

Both Tom and Priya hold biometric UK passports and active GOV.UK One Login accounts from their personal tax filings. They self-verify via the One Login app in late November 2025, immediately after the 18 November mandatory commencement. Each receives a personal code from Companies House. The whole exercise takes about ten minutes per person and costs nothing. Their accountant captures both codes in the firm's client file for use in the next confirmation-statement cycle.

Personal-code provisioning by SPV

  • Calder Properties Ltd: confirmation date 22 May; filing window closes 5 June 2026. Tom provides his personal code at that filing. As at the writing of this page, this is the next imminent filing.
  • Trent Holdings Ltd: confirmation date 12 August; filing window closes 26 August 2026. Tom and Priya each provide their personal codes at that filing.
  • Aire Investments Ltd: confirmation date 22 November; filing window closes 6 December 2026. This sits just AFTER the 12-month transition window ends, so it is operationally the cleanest of the three; Tom and Priya each provide their personal codes.

What would have triggered an earlier deadline

If Tom had appointed a new director to any of the three companies between 18 November 2025 and the next confirmation date (the most common trigger being a new spouse-director added for income-splitting reasons), the new director's appointment filing itself would have been a verification gate independent of the confirmation-statement cadence. New appointments since 18 November 2025 require the appointee's personal code at the appointment filing, not at the next confirmation statement.

The ACSP route in more detail

For landlords whose accountant is taking on the verification work directly, the ACSP route involves a small set of operational steps:

  1. The accountant confirms it is registered as an ACSP on the Companies House service. Registration is open to UK firms that are supervised for anti-money-laundering purposes under the Money Laundering Regulations 2017 (typically by HMRC or by their professional body such as ICAEW, ACCA or ICAS for accountants, and the SRA for solicitors). The firm signs up to a code of conduct and accepts the regulatory requirements that come with ACSP status.
  2. The accountant collects the documents needed for verification. For most landlord-director clients the AML file already includes a certified passport scan, proof of address and tax-relevant ID; the same documents satisfy the verification standard, refreshed if more than three months old.
  3. The accountant submits the verification to Companies House through the ACSP service. Companies House issues the personal code to the client (or to the accountant for onward transmission, depending on the ACSP service configuration).
  4. The code is then quoted by the accountant on the client's behalf in the next confirmation statement, director-appointment filing or PSC-notification filing.

The cost varies by firm; typical pricing as at the writing of this page is between £50 and £150 per natural person verified, often bundled into the firm's annual fee for company-secretarial work. The marginal cost falls quickly across a portfolio because the per-person AML file is the substantive work, not the per-filing code provision.

What happens if you do not verify in time

The consequences run on two interlocking tracks.

The offence and the financial-penalty exposure

It is an offence under ECCTA 2023 for an individual to continue acting in a Companies Act 2006 role to which the verification regime applies without having completed verification. The offence is committed by the natural person, not by the company; financial penalties run against the individual and can also extend to the company where the company files or attempts to file using the missing personal code. The current maximum financial penalty cited on the gov.uk confirmation-statement guidance page is £5,000 per missed confirmation statement, alongside annotation on the public register against the individual. The exact penalty structure for the ID-verification offence sits in ECCTA's offence provisions; we suggest sessions verify the operative wording against legislation.gov.uk at the point of formal advice rather than relying on summary cites.

The filing block and the striking-off risk

The more immediate operational consequence is that Companies House will reject filings that require a personal code where the code is missing. A confirmation statement filed without the personal codes for in-scope directors and PSCs is incomplete and is not accepted. A company that misses two consecutive confirmation statements is in the registrar's striking-off line under Companies Act 2006 s.1000. Striking off is reversible by administrative restoration for six years from dissolution, but the company is dissolved in the interim and its assets vest in bona vacantia. For a property-holding LtdCo where the company owns title to actual property, a striking-off event creates serious title and refinance problems that can take months to unwind even after restoration.

The practical message: do not let the verification gate cause a missed confirmation statement. The downstream consequences are out of proportion to the cost of the verification itself.

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Where ID verification sits alongside the other 4 March 2024 confirmation-statement changes

The annual confirmation statement now bundles four operational obligations introduced or amended by ECCTA 2023 across 2024 to 2026:

  1. The registered office must be an "appropriate address" capable of acknowledging delivery of documents (in force 4 March 2024). PO-box-only addresses no longer qualify.
  2. A registered email address must be supplied (in force 4 March 2024). Companies House uses the email for company-to-registrar correspondence; it is not published on the public register.
  3. A lawful-purposes statement must be made on every confirmation statement (in force for statements dated on or after 5 March 2024).
  4. The personal code for each in-scope director and PSC must be quoted (operational from 18 November 2025 for new appointments, with the 12-month transition window for existing roles).

For a landlord who is filing the 2026 confirmation statement for an SPV, all four of these elements are now part of the routine filing rather than the company-incorporation moment. The accountant or company-secretarial agent who runs the confirmation-statement run for the portfolio is the natural integrator of these four operational pieces. Our companion page on the post-March-2024 confirmation-statement changes for landlord LtdCos covers the other three obligations in detail; this page focuses on the verification and personal-code mechanic that sits inside the broader filing.

Practical checklist for a multi-SPV landlord planning verification

  1. Enumerate the natural-person headcount across the portfolio. Every director and every 25%-plus shareholder counts. Family Investment Company structures and trust-owned SPVs sometimes carry a longer list than the founder anticipates.
  2. Decide the route per natural person. Founders comfortable with GOV.UK One Login and the app process should self-verify. Founders preferring a single accountant-led process should authorise the ACSP route via their firm.
  3. Verify once, capture the code centrally. The accountant should record the personal code in the client file (treating it with the same confidentiality as a Unique Taxpayer Reference) so it is available for every filing across the portfolio for that natural person.
  4. Sequence the filings against confirmation dates. The earliest confirmation date in the portfolio sets the latest verification deadline. Work backwards from there with a comfortable buffer.
  5. Plan for new appointments. Any new director or new 25%-plus shareholder added to any SPV since 18 November 2025 is an independent verification trigger at the appointment-related filing, not at the next confirmation statement.
  6. Watch the second phase. Filers and corporate-officer scenarios are scheduled to come into scope no earlier than November 2026. Landlord structures using overseas corporate holding companies above UK SPVs should monitor the campaign page for the second-phase commencement.

Where to check the operative state at any future point