The Government has made the Companies and Limited Liability Partnerships (Annotations, Application and Modification of Company Law and Consequential Amendments) Regulations 2025 (SI 2025/1116), aligning multiple company‑law measures with the start of mandatory identity verification on Tuesday 18 November 2025. The instrument was made on 22 October and laid on 23 October.
From commencement, the registrar must add a public note against an individual’s record when Companies House confirms that the person’s identity is verified. The trigger is the notice issued under the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025, integrating the new verification workflow with visible register annotations.
Filings that state someone’s identity is verified will also need that individual’s Companies House unique identifier (the “personal code”). Companies House confirms that from 18 November people will provide this code alongside a verification statement for each role they hold. This creates a consistent audit trail across appointments and changes.
The instrument applies the same annotation duty to the LLP register and synchronises commencement with the LLP prohibition on acting unless identity‑verified. In practice, section 167M of the Companies Act 2006 (as adapted for LLP members by regulation 17AA) will go live in the same window as company directors.
For LLP filings, the instrument updates the information Companies House expects on member notifications and confirms that the registrar’s unique‑identifier framework will be used when a filing states that a member’s identity is verified. This mirrors the unique‑identifier regime already set out in the verification regulations.
Unregistered companies are brought into scope for these annotation powers. The registrar may note verified identity status and, where relevant, place annotations where material on the register could mislead, where director disqualification sanctions apply, or where a person has not complied with a notice to provide information under section 1092A of the Companies Act 2006.
The instrument also makes technical updates to the Registered Office Address (Rectification of Register) Regulations 2024 by removing references to inspection duties linked to local statutory registers that are being replaced by a strengthened central register. This tidies the regime that underpins Companies House action on inappropriate addresses.
A cross‑reference in the 2025 regulations for companies authorised to register is corrected so that the unique‑identifier provisions now point directly to the 2025 verification regulations. This ensures that where a filing asserts identity‑verified status, the unique identifier required by Companies House is unambiguous.
For overseas companies, the new instrument clarifies the transitional drafting so that references are to the offence provisions in section 167M(3) and (4), not to the underlying prohibitions in section 167M(1) and (2). That aligns the text with the structure of section 167M, where subsections (3) and (4) create the offences.
Transitional arrangements for unregistered companies require an identity verification statement for existing directors to be delivered with the next confirmation statement in the transitional window. If a statement is overdue at go‑live, there is a short grace period, after which the offence provisions begin to apply. The approach aligns with Companies House’s 12‑month phasing plan.
Identity verification for LLPs follows the same design principle: existing individual members will confirm verified status in step with the LLP’s next confirmation statement once the prohibition on acting unless verified is in force. This maintains parity between companies and LLPs as ECCTA measures are applied.
For company secretaries and compliance teams, the immediate tasks are operational. From 18 November, check that appointment and change forms include the personal code where a filing states identity‑verified status; expect to see a “verified” note appear on director and LLP member records; and align internal calendars so that existing individuals verify on or before the next confirmation statement due within the 12‑month phase‑in. Companies House will also publish identity‑verification due dates by role to support planning.