The Department for Business and Trade has made the Companies and Limited Liability Partnerships (Annotations, Application and Modification of Company Law and Consequential Amendments) Regulations 2025 (SI 2025/1116). The instrument was made on 22 October 2025 and laid on 23 October 2025. Most provisions commence in step with Companies Act 2006 section 167M (the prohibition on a director acting unless identity verified). Companies House has separately confirmed that mandatory identity verification for directors and people with significant control will begin on 18 November 2025, with a 12‑month transition.
A new annotation duty is introduced. When the registrar confirms-under the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025-that an individual’s identity is verified, Companies House must place a note on the public register stating that verified status. The same requirement is applied to the LLP register by read‑across to section 1080(2) of the Companies Act 2006. This creates a visible, authoritative marker that an individual linked to a filing, appointment or control statement has passed identity checks under the 2025 framework.
Unique identifiers are embedded into filings that include a statement that an individual’s identity is verified. For those filings, the statement must also set out the individual’s unique identifier. The allocation and administration of unique identifiers (the Companies House personal code issued on verification) follow the Registrar Regulations 2025. From 18 November, directors and PSCs will need to provide this personal code each time they confirm a role, ensuring consistent linkage across records.
For LLPs, SI 2025/1116 updates the information that must be notified about members. It removes the nationality field for individual members and the service‑address field for corporate members, and requires a new flag indicating whether a person is a designated member. The instrument also ties LLP filings that state an individual is identity‑verified to inclusion of that person’s unique identifier, aligning LLP practice with company requirements under the identity‑verification regime.
The instrument extends Companies Act 2006 section 1081 annotation powers to unregistered companies. The registrar may annotate where register material is misleading or confusing, where a person shown as a director is known to be subject to director‑disqualification sanctions (with licence details noted where applicable), and where a recipient has not complied with an information notice under section 1092A. A verified‑ID note must also be added for unregistered companies when confirmed by the registrar.
Consequential amendments refine privacy and certification rules for unregistered companies. Companies Act 2006 section 1087 (material not available for public inspection), section 1087C (disclosure of date‑of‑birth information) and section 1091 (certification of copies) are applied with modifications so that the existing Companies House regimes on withheld material and electronic certification operate consistently across these entities. This aligns unregistered‑company filings with company and LLP practice set earlier in 2025.
There are further technical corrections. The Companies (Companies Authorised to Register) Regulations 2009 are updated so their cross‑references point to the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025 (SI 2025/50). The Registered Office Address (Rectification of Register) Regulations 2024 are also tidied to remove now‑redundant text linked to local statutory registers repealed by the Economic Crime and Corporate Transparency Act 2023.
For companies authorised to register, unregistered companies and overseas companies, SI 2025/1116 dovetails with the sector‑wide framework adopted earlier in 2025. The July 2025 instrument on application of company law (SI 2025/761) already set identity‑verification expectations and offence provisions for these entities; the new regulations correct cross‑references and ensure annotations and unique‑identifier practices operate on the same basis as for UK‑incorporated companies.
Transitional arrangements for unregistered companies are recast. Where an individual became a director before the relevant day (defined by ECCTA 2023 section 43 coming into force), the company must deliver an identity verification statement for that director with its next confirmation statement during the 12‑month transitional period. If the confirmation‑statement window has not yet begun or is in train on the relevant day, the section 167M offence does not bite until the company files that statement or the delivery period ends. If a confirmation statement is already overdue on the relevant day, the safe period ends on the earlier of compliance or 14 days after that day. The provisions fall away if the person is no longer a director at the relevant time.
Equivalent transitional rules are applied to LLPs. For any individual who became a member before the relevant day, the LLP must deliver an identity verification statement at the same time as its next confirmation statement during the 12‑month transitional window, with the same safe‑harbour mechanics where a confirmation‑statement period has not yet begun or is ongoing, and a 14‑day limit where one is overdue. The duties do not apply if the person has ceased to be a member by the time the filing falls due. These provisions align with the wider LLP reforms adopted alongside the identity‑verification regime.
For practice, company secretaries and compliance leads should treat the verified‑ID note as a live status indicator and record the unique identifier for each relevant individual in entity‑management systems. From 18 November 2025, officers and PSCs will be expected to verify and use their personal code across roles, either through GOV.UK One Login or via an Authorised Corporate Service Provider. This avoids rejected appointments and ensures confirmation statements carry the required verification data.
The offence position is unchanged in principle but becomes operational. Acting as a director or, for LLPs, as a member without being identity‑verified after the regime goes live is a summary offence, with the company or LLP also at risk where it allows unverified participation. The registrar’s expanded annotation powers-covering verified status, disqualification and non‑compliance with information notices-mean that enforcement signals will be visible on the public record alongside the underlying filings.
Overall, SI 2025/1116 stitches the verified‑identity framework into the mechanics of the register. It directs when the public record must show verified status, mandates use of unique identifiers in key filings, and updates transitional rules so pre‑existing directors and LLP members can regularise their status through the confirmation‑statement cycle that starts on and after 18 November 2025.