The Government has signed the Economic Crime and Corporate Transparency Act 2023 (Commencement No. 6 and Transitional Provisions) Regulations 2025, activating the next phase of Companies House reform from Tuesday 18 November 2025. From that date, identity verification becomes a legal requirement for new directors and is phased in for existing directors and people with significant control (PSCs) over 12 months, according to Companies House.
Key offences created by the 2023 Act also switch on. Section 43 makes it an offence for an individual to act as a director, or for a company to permit it, unless the individual’s identity has been verified. Section 44 separately makes it an offence for a person to act as a director if their appointment has not been notified to the registrar within the statutory deadline. These provisions are designed to ensure verified, up‑to‑date director data on the public register.
The commencement also brings into force updates to the directors’ disqualification regime. Amendments to the Company Directors Disqualification Act 1986 and the Northern Ireland Order allow disqualification for persistent breaches of relevant companies legislation, including repeated filing failures and identity‑verification defaults. This widens what can count as a ‘default’ beyond convictions to include financial penalties.
Transitional rules for existing directors are central to compliance planning. For anyone who became a director before 18 November 2025, the company must deliver an identity‑verification statement for that individual at the same time as it files its next confirmation statement within a 12‑month transitional period. During that window, the Act’s prohibition on acting while unverified is paused until the company reaches its next confirmation‑statement filing point. Companies with an overdue confirmation statement on 18 November 2025 face a shorter grace period that ends once they file or at the end of 2 December 2025, whichever is earlier. (These timings are set in the Commencement No. 6 Regulations.)
PSCs are subject to a separate timetable. For existing PSCs who are also directors (and whose particulars are not protected), their ‘appointed day’ for initial verification aligns with the company’s first review period ending within the year after 18 November 2025. For existing PSCs who are not directors, the appointed day is tied to the first day of the month shown for their date of birth on the register, with a 14‑day window to submit a verification statement; Companies House gives the example of a PSC with “March 1990” starting on 1 March 2026. New PSCs registered after 18 November 2025 must verify within 14 days of registration.
The reforms also remove the need for companies to maintain local statutory registers of directors, directors’ residential addresses, secretaries and PSCs from 18 November 2025. Those records move to Companies House as the definitive source, while companies must still maintain their own register of members. Companies will be expected to notify Companies House of changes to PSC details within 14 days of having confirmation of a change.
For company secretaries, the practical sequence is clear. First, ensure every serving director verifies their identity and has a Companies House personal code ready ahead of the next confirmation statement after 18 November 2025. Second, map PSC verification deadlines using the appointed‑day rules, paying particular attention to PSCs who are not directors, whose 14‑day windows run from the first day of their birth month in 2026. Third, switch internal processes from maintaining local officer and PSC registers to prompt central filings with Companies House.
From 18 November 2025, newly appointed directors must be verified before acting and must not act until the company has filed the appointment notice. For existing directors, the prohibition on acting while unverified bites immediately after the relevant confirmation‑statement delivery period unless the identity‑verification statement has been filed on time. This sequencing is intended to avoid disrupting governance while directing compliance effort to known filing points.
Some elements are deferred. The Commencement No. 6 Regulations do not yet start provisions requiring registrable relevant legal entities (corporate PSCs) to maintain a verified ‘registered officer’, nor the service‑address obligations for corporate directors and RLEs. Companies House also confirms that identity‑verification requirements for limited partnerships, corporate directors, corporate LLP members and officers of corporate PSCs will commence later.
Public access to sensitive verification data remains restricted. Individuals receive a personal code to connect their verified identity to each role; this code is used in filings but is not a public identifier, and verification material submitted through GOV.UK One Login is not placed on the public record.
Enforcement will scale with the regime. Acting as a director while unverified, or before the appointment has been notified, is a summary offence; repeated non‑compliance with filing and verification duties can now support a disqualification order. Companies House has said it will take a proportionate approach to enforcement during the transition, but penalties and disqualification are available where necessary.
The immediate task for boards is to fix verification into routine corporate housekeeping: align director and PSC verification with confirmation‑statement cycles, update appointment procedures so no director acts before filing and verification, and retire local officer and PSC registers in favour of prompt filings to the central register from 18 November 2025. That approach will minimise exposure to the new offences and the strengthened disqualification regime while meeting the statutory timetable.