New regulations laid before Parliament on 23 October 2025 require the registrar to mark the public register when an individual’s identity has been verified. The instrument aligns with the Economic Crime and Corporate Transparency Act 2023 and will commence alongside Companies Act 2006 section 167M, which makes it an offence to act as a director unless verified. Companies House has confirmed Tuesday 18 November 2025 as the start date, with a 12‑month transition for existing roles.
In practical terms, when the registrar issues a notice under regulation 8(1) or regulation 12(1) of the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025 confirming an individual’s identity, a note must be placed on the register stating that verification. The same duty is applied to the LLP register so the status is visible for members as well.
The instrument adjusts LLP member records so filings are focused on data Companies House will use at go‑live. Individuals will provide name and date of birth and indicate whether they are designated members. Nationality is not required at this stage. For corporate members, the obligation to file a service address is deferred until Companies House implements that field.
Unique identifiers move centre‑stage. Chapters 1 and 2 of Part 4 of the 2025 Registrar Regulations now apply to LLP dealings with the registrar, and wherever legislation requires a statement that an individual’s identity is verified, that statement must also include the individual’s unique identifier. ECCTA 2023 amended Companies Act 2006 section 1082 so verified individuals and authorised corporate service providers are within scope of the unique identifier scheme.
For unregistered companies, the registrar’s annotation powers are extended. Notes may be added where information appears misleading or confusing, where a person shown as a director is subject to director disqualification sanctions, or where a recipient has not complied with an information notice issued under Companies Act section 1092A by the deadline. The registrar must also annotate when an identity verification outcome confirms an individual as verified.
The rules are timed to keep the people‑with‑significant‑control (PSC) regime in step. A PSC‑related provision switches on immediately after Companies Act section 790LA (duty to notify confirmed PSCs) commences, ensuring that PSC notifications and the new annotation and unique identifier requirements align.
Transitional arrangements for unregistered companies are explicit. Where an individual became a director before 18 November 2025, the company must deliver an identity verification statement for that person with its next confirmation statement during the 12‑month transition. If a confirmation statement is already overdue on the relevant day, the grace period is shorter. While that window is open, the section 167M prohibition on acting while unverified is disapplied for the individual and the company.
A matching transition applies to LLPs. Any individual who became a member before 18 November 2025 must have an identity verification statement delivered with the LLP’s next confirmation statement within the 12‑month period. During that period, enforcement of the section 167M prohibition is deferred for those members until the statement is filed or the delivery period ends.
Two corrective changes are also included. First, the 2025 regulations for overseas companies are updated so their transitional cross‑references point to the correct subsections of section 167M. Second, the Registered Office Address (Rectification of Register) Regulations 2024 are tidied to remove references that assumed companies still kept certain local registers, reflecting ECCTA’s abolition of those registers.
Personal data handling for unregistered companies is clarified. The Companies (Disclosure of Date of Birth Information) Regulations 2015 are applied so that full dates of birth remain protected from public inspection in line with the position for companies.
For governance teams, the operational task is straightforward but urgent: capture unique identifiers in appointment and change‑of‑details workflows, gather identity verification statements alongside confirmation statements during the transition, and prepare for visible ‘identity verified’ markers on officer records. The instrument was laid on 23 October 2025 under the negative procedure.