If you are a US resident who is (or is becoming) a director or person with significant control (PSC) of a UK private limited company, the Economic Crime and Corporate Transparency Act 2023 now requires you to verify your identity at Companies House. The rule has been a legal requirement for newly appointed directors and PSCs since 18 November 2025, and existing directors and PSCs in post before that date must verify by their next confirmation statement within the twelve-month transition window closing around November 2026.

The practical reality for US-resident directors is that the simplest route is not GOV.UK One Login, which is designed and optimised for UK-resident sign-up. The practical preferred route is a UK-authorised Authorised Corporate Service Provider (ACSP) under ECCTA s.66 who can accept your US identity documents under their Money Laundering Regulations 2017 supervision and complete the Companies House verification on your behalf without you ever having to obtain a UK-issued document. This page is the complete operational walkthrough for the US-resident route.

For the UK-resident director walkthrough, see our ECCTA 2023 identity verification for landlord LtdCos page. For the broader identity-verification framework, see our complete guide to identity verification in the UK.

Can I Verify Identity from the US Using GOV.UK One Login?

Technically yes if you can complete the GOV.UK One Login flow, but in practice the service is designed and optimised for UK-resident users with UK-issued identity documents (UK driving licence, UK passport, UK address). US-resident users may face friction at several points:

  • The document-photo-and-face-match flow accepts a US passport, but the wider user journey assumes a UK address-history anchoring step that does not work cleanly for a US-domiciled user.
  • Some elements of the address-verification step query UK-side credit-bureau equivalents that do not return data for a US-resident.
  • The customer-support pathway for a stuck user is optimised around UK working hours and UK telecoms numbers; resolving a stuck verification from the US can take materially longer than from the UK.

The GOV.UK One Login operational user-journey is evolving; verify the current US-resident user experience against the live gov.uk guidance before assuming the route works. The practical preferred route is the ACSP route, which removes the user-journey friction by delegating the Companies House submission to a UK-side professional who handles the US-document acceptance under their MLR 2017 supervision.

The ACSP Route: Why It Is the Practical Preferred Route

An Authorised Corporate Service Provider is a firm AML-supervised under MLR 2017 (typically a UK accountant, company-secretarial firm, or solicitor) that has registered with Companies House to perform identity verification on behalf of clients under ECCTA s.66. For US-based directors, the ACSP route offers four operational advantages.

  • US-document fluency. The ACSP is regulated by an AML supervisor (HMRC, FCA, ICAEW, ACCA, ICAS, CIOT, Law Society, or equivalent) that has approved its identity-verification procedures, including the acceptance of US-issued documents.
  • Submission-by-proxy. The ACSP completes the Companies House submission on the US director's behalf. The US director never engages directly with the GOV.UK One Login flow.
  • One-off fee, permanent code. The ACSP fee is typically £150 to £300 one-off (verify against the chosen firm's published rates). The personal code issued under ECCTA s.68 is permanent and covers every UK directorship and PSC interest the US director will ever hold across every UK company.
  • Ongoing relationship value. The ACSP can fold the identity verification into a broader UK-side adviser engagement (confirmation statements, share-register maintenance, annual compliance, board-meeting administration), avoiding the need for separate UK-side professional relationships.

Which US Identity Documents the ACSP Accepts

Under MLR 2017 and Companies House published ID-document standards, ACSPs typically accept the following.

Photo Identity (Primary)

  • US passport. The primary accepted document; used by the majority of US-resident clients. Machine-readable security features and biometric chip support remote verification cleanly.
  • US state-issued driver's license. Typically acceptable as a primary photo ID, often supplemented by a secondary document for address-of-residence verification.
  • US military ID. Acceptable for serving members.
  • US permanent-resident card (green card). Acceptable for green-card holders.

Address-of-Residence (Secondary)

  • US utility bills (electricity, gas, water, telecoms) dated within the last three months.
  • US bank statements dated within the last three months.
  • US state-issued formal address-verification letter.
  • US property-tax bill or mortgage statement.

Supplementary

  • US Social Security card may be used as a supplementary identity-verification document, particularly where a primary document needs cross-checking.

Each ACSP firm operates under its own MLR 2017-approved document policy. The chosen ACSP's published acceptance list should be reviewed before document submission. Documents not in English typically require certified translation. Older US state IDs that lack machine-readable security features may not be accepted.

The ACSP Fee and Workflow

Typical workflow over five to ten business days.

  1. Engagement. US director contacts ACSP, reviews the engagement letter and the firm's MLR 2017 onboarding pack, and signs.
  2. Document submission. US director uploads US identity documents via the ACSP's secure encrypted KYC portal. Most ACSPs use established cloud KYC platforms (Onfido, Veriff, Yoti, Jumio) which are designed for cross-border identity capture.
  3. Video-verification call. ACSP conducts a 15-to-30-minute video call, scheduled around US/UK time zones, during which the US director shows the ID, the live face, and answers questions to satisfy the document-and-face-match standard.
  4. Database checks. ACSP runs underlying checks (sanctions screening, PEPs screening, US background checks via approved providers) and documents the verification file.
  5. Submission to Companies House. ACSP submits the identity verification request to Companies House on behalf of the US director under the firm's ACSP authorisation.
  6. Personal code issuance. Companies House issues the personal code under ECCTA s.68; the ACSP receives confirmation.
  7. Delivery to the US director. ACSP delivers the personal code and the confirmation documentation, typically by secure email or via the engagement portal.

Typical fee: £150 to £300 one-off. Some ACSPs bundle the verification into broader UK-side adviser packages, with the verification fee absorbed into a wider engagement letter. Some firms charge per directorship rather than per natural person; most apply the per-natural-person standard reflecting the way the personal code actually works under ECCTA s.68. The personal code is permanent and one verification covers every UK directorship and PSC interest across the US director's lifetime.

Time Zones and Remote Video-Verification Mechanics

The US/UK time-zone spread is five to eight hours depending on the US time zone:

  • Eastern Standard Time: UK is five hours ahead (EDT in summer, four hours ahead).
  • Central Standard Time: UK is six hours ahead.
  • Mountain Standard Time: UK is seven hours ahead.
  • Pacific Standard Time: UK is eight hours ahead (PDT in summer, seven hours ahead).

ACSP video-verification calls are typically scheduled within UK working hours (8am to 6pm GMT/BST), which translates to early-morning-US for the East Coast (3am to 1pm EST) and middle-of-night-US for the West Coast (12am to 10am PST). Most ACSPs serving US-resident clients offer flexible scheduling with extended hours (some until 9pm UK time, equivalent to 4pm EST or 1pm PST). Some ACSPs accept pre-recorded video verification with separate quality-control review, which removes the live-scheduling constraint entirely.

Document transmission is via secure cloud KYC platforms; no postal exchange of documents is required and no original documents leave the US director's possession. The remote-verification standard meets MLR 2017 and Companies House requirements where the document-and-face-match meets KYC standards.

The 18 November 2025 Commencement and the 12-Month Transition Window

Two-track deadline regime.

New Appointments (from 18 November 2025)

If you are being newly appointed as a director or PSC of a UK company on or after 18 November 2025, you must be verified before the appointment can be filed at Companies House. The ID verification and personal code allocation must complete before the AP01 (appointment of director) or PSC01 (notice of relevant individual) filing. Companies House will not process the appointment without a quoted personal code from 18 November 2025 onwards.

Existing Appointments (transition window closing around November 2026)

If you were a director or PSC of a UK company before 18 November 2025, you have a twelve-month transition window to be verified by your next confirmation statement filed within the window. The precise per-company deadline is anchored to the confirmation-statement cycle of each UK company you serve. If you are a director of three UK companies with confirmation statements due in February 2026, May 2026, and September 2026, you must be verified before the earliest of those filing dates (February 2026) to ensure all three filings can proceed cleanly through the year.

Critically, one natural-person verification covers every UK directorship and PSC interest you hold. You do not need to verify separately per company. The personal code travels with the person, not with the company.

FATCA, Form 5471, FBAR, and ECCTA: The Four-Way US/UK Disclosure Overlap

Four parallel disclosure obligations operate on US persons connected to UK companies. They are independent, not substitutable. Completing one does not satisfy any of the others.

  1. UK ECCTA Companies House verification and public-register disclosure (UK-side). The topic of this page. Verified identity, permanent personal code, public-register entries on directorship and PSC interest and share capital. UK-side only.
  2. IRS Form 5471 (US-side). US persons who are officers, directors, or 10%+ shareholders of foreign (non-US) corporations must file Form 5471 annually with their US federal tax return. Multiple categories (1 through 5) apply depending on level of ownership and officer status. Substantial reporting requirements and significant penalties for non-filing (typically $10,000 or more per failure, with stacking of penalties for multiple-year defaults).
  3. FBAR / FinCEN Form 114 (US-side). US persons with financial interest in or signature authority over foreign financial accounts with aggregate value above $10,000 at any point in the calendar year must file FBAR annually. UK company bank accounts are reportable; the US director who has signature authority over the UK company's bank account is in scope.
  4. IRS Form 8938 / FATCA (US-side). US persons with specified foreign financial assets above certain thresholds must file Form 8938 with their US federal tax return. The thresholds vary by filing status and residence.

Each of these obligations is independent. Completing the UK ECCTA verification does not satisfy any of the US-side reporting obligations and vice versa. We are a UK firm and we handle UK-side ECCTA and UK tax. We do not advise on US-side compliance; engage a US-qualified CPA or tax adviser for Form 5471, FBAR, and Form 8938 obligations. Practical coordination between a UK ACSP and a US CPA is the standard operational pattern for cross-border private clients.

UK/US Double Tax Treaty Implications

Where the US director receives UK-source income (dividends from the UK company, management fees, rent passed directly), the UK/US Double Tax Treaty (1975 / 2001 protocol) allocates taxing rights.

  • Article 4 (residence tiebreaker). Typically clear for a US-resident-only individual with a UK company: US residence wins for treaty purposes.
  • Article 6 (immovable property). UK property income is UK-taxed even where the shareholder is US-resident. The Non-Resident Landlord Scheme applies to direct rental income; for UK-LtdCo-held rental, the company pays UK corporation tax and the dividend to the US shareholder is treaty-rate withheld under Article 10.
  • Article 10 (dividends). UK withholding tax on dividends to a US-resident shareholder is treaty-rate capped at 15% in the portfolio case, with lower rates available for qualifying substantial-shareholder cases.
  • Article 13 (capital gains). UK CGT on UK property bites a US-resident shareholder under UK Non-Resident CGT rules even where the treaty would otherwise allocate to the US.

US-side foreign tax credit is available on the US federal return for UK tax paid, subject to the standard FTC rules. The treaty side is a separate tax matter from the ECCTA verification, but the same US director typically faces both at the same time and the operational coordination across UK and US advisers is the practical answer.

Consequences of Non-Verification

Three-layer consequence stack.

One: Blocked Companies House Filings

Confirmation statement filings cannot proceed without a personal code from each in-scope director and PSC. The company falls into default on its Companies Act 2006 s.853A duty to deliver a confirmation statement and accrues civil penalty under Schedule 1B of the Companies Act 2006 (up to £5,000 per failure). For multi-SPV portfolios, the penalty stacks per SPV per missed filing.

Two: Criminal Offence for Continuing to Act Unverified

Once the transition window closes (around November 2026 for existing roles; immediately for new appointments from 18 November 2025), continuing to act as a director or PSC without a personal code is an offence under the relevant ECCTA-inserted provisions in the Companies Act 2006. Verify the precise section attribution against the current Companies Act text at write.

Three: Director Disqualification and Striking-Off Exposure

Companies House may pursue director disqualification proceedings under the Company Directors Disqualification Act 1986, or strike-off proceedings against the company itself under Companies Act 2006 ss.1000-1011 for continued non-compliance. For US-resident directors, criminal-track enforcement raises cross-border-enforcement questions, but the civil-penalty route and the strike-off route are operationally significant regardless of residence. A strike-off dissolves the UK company; its assets vest in the Crown bona vacantia; refinancing, sale, and ongoing trading become impossible. For a US-resident shareholder whose UK company is the holding vehicle for UK property, a strike-off is materially destructive.

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Practical Compliance Checklist for US-Based Directors

  1. Identify every UK directorship and PSC interest you currently hold or are about to take up. Multi-vehicle US-resident family structures often have more UK directorships than the principal advisers initially recall.
  2. Identify the confirmation-statement filing date for each UK company at the Companies House Find and update company information service.
  3. Determine your earliest required-verification date. For new roles, before the appointment can be filed. For existing roles, before the next confirmation statement after 18 November 2025 within the transition window.
  4. Select a UK-authorised ACSP. Typically your UK accountant or company-secretarial agent. Verify the firm is registered as an ACSP at Companies House and AML-supervised under MLR 2017.
  5. Gather US identity documents. US passport (primary), US driver's license, US utility bills dated within the last three months, US bank statement dated within the last three months.
  6. Book the ACSP video-verification call and complete onboarding within five to ten business days. Allow extra time around US East Coast morning hours for scheduling availability.
  7. Receive and record the personal code. The code is permanent and covers every UK directorship and PSC interest you will ever hold. Store it securely with your UK-side adviser records.
  8. Quote the personal code on each subsequent confirmation statement and appointment filing.

Separately, engage a US-qualified CPA or tax adviser to address Form 5471, FBAR, Form 8938, and FATCA US-side obligations. These are independent of the UK ECCTA verification and require US-qualified expertise.

US-Resident PSCs Who Are Not Directors

The verification regime applies to both directors and PSCs. A US-resident family member who is a 25%+ shareholder (or otherwise qualifying PSC under the Companies Act 2006 PSC tests) of a UK family investment company or UK property-SPV but who is not a director must still be ID-verified. The same ACSP route applies, the same deadline regime applies, and the same one-natural-person-one-personal-code architecture applies.

For multi-generation US-resident family structures (typically a US-resident founder plus US-resident adult children plus, sometimes, US-resident grandchildren above the 25% threshold), each US-resident PSC must individually verify. The verifications can be batched through a single ACSP engagement to streamline the cost and the scheduling, but each natural person needs their own personal code.

US LLCs as Members or Directors of UK Companies

For a US LLC as a shareholder of a UK company (the most common pattern), the LLC is a 'person' for PSC purposes but the PSC architecture looks through to the LLC's ultimate beneficial owners. The natural persons behind the US LLC may themselves be in-scope PSCs requiring individual verification under the look-through mechanic in the Companies Act 2006 PSC regulations.

For a US LLC serving as a corporate director of a UK company, the ECCTA 2023 reforms restrict corporate directors generally. The current operative restriction position should be verified against the live Companies House guidance at write. For most US-resident family structures, the operational answer is that the US natural persons behind the US LLC will need to verify individually rather than relying on the LLC as a corporate director.

UK Expats with Continuing UK Directorships

US-resident UK expats are a common reader-profile: UK nationals who have emigrated to the US and retained UK directorships and PSC interests in UK family companies, FICs, or UK property structures. The same ECCTA verification regime applies. The ACSP route works equally; UK identity documents (UK passport, UK driving licence) remain acceptable even after emigration. Some UK expats hold both US-issued documents (green card, US driver's license) and UK-issued documents (UK passport); the ACSP accepts whichever is most operationally convenient.

Additional UK-side considerations for the expat: the Statutory Residence Test affects ongoing UK income-tax and CGT exposure; the long-term-residence regime under the Inheritance Tax Act 1984 affects IHT exposure for expats with substantial UK assets. These are wider tax matters distinct from the ECCTA verification but they often surface in the same conversation when the verification triggers a wider UK-side compliance review.

ECCTA Verification Versus the Register of Overseas Entities

Different registers, different consequence stacks. Easy to confuse for US-resident readers because both involve UK transparency reform and both can affect the same family.

  • ECCTA verification is the companies-side register: UK private companies and LLPs and their natural-person directors and PSCs. This page covers it. The block on non-compliance is at the Companies House confirmation-statement filing.
  • Register of Overseas Entities is the separate overseas-entities register for overseas legal entities (BVI, Jersey, Guernsey, Cayman, Delaware LLC) that own UK property. The block on non-compliance is at HM Land Registry on every disposition. For the RoE consequence stack, see our consequences for RoE non-compliance page.

A US-resident director of a UK private limited company that owns UK property faces the ECCTA verification regime (this page). A US-resident officer or beneficial owner of a Delaware LLC that directly owns UK property faces the RoE regime. Both regimes can affect the same family across different vehicles, and US-resident clients with both UK-LtdCo and Delaware-LLC structures need to navigate both compliance tracks in parallel.

Authorities Cited