Identity verification became a legal requirement at Companies House on 18 November 2025, and it arrived without the noise that usually accompanies a change of this size. There was no filing deadline on the day, no penalty notice in the post, and nothing stopped working. That is precisely why so many companies have not dealt with it.
The numbers say so plainly. Companies House publishes its own compliance figures, and at the end of June 2026 — more than seven months in — 55.3% of director appointments and 41.9% of individual PSC appointments had been verified (Companies House management information, April to June 2026). Across all appointment types, 7,364,599 had verified and just under half had not. Nearly three in five individual PSCs were still outstanding.
For a startup, the consequence is specific and badly timed. A confirmation statement is rejected unless every director has verified. The confirmation statement is the filing that tells the world who owns and runs your company, and the moment it matters most is the moment an investor's lawyer opens your filing history.
What each person actually has to do
The rules differ by the role someone holds, not by the person, and one individual can carry two duties at once with two different clocks running.
- An existing director of an existing company. You give your Companies House personal code as part of the company's next confirmation statement. That is the operative deadline for most companies, and it is the one that bites, because the filing simply will not be accepted without it.
- A new director. The personal code for every director is required as part of the registration filing itself. You cannot incorporate around it.
- Someone who is both a director and a PSC. The code has to be provided separately for each role, within 14 days of the confirmation statement date. Two roles, two entries — a genuinely easy thing to half-do.
- A PSC who is not a director. This is the one founders never see coming, because it is not tied to the company's calendar at all. A PSC-only individual must provide their code within the first 14 days of their own birth month. Your investor's duty is scheduled by their birthday, and nobody at your company will be reminded of it.
- A PSC added since 18 November 2025. Verification is due when they are first added to the register, or within 14 days of being added.
Verification itself is not the hard part. It takes minutes through GOV.UK One Login, or it can be done through an authorised corporate service provider. What comes back is an 11-character personal code, and that code belongs to the person rather than the company: verify once, and the same code covers every board you sit on.
Why this lands harder on a funded startup
A company with one director and one shareholder has one person to chase. A startup that has raised money has a register that changes, and each change quietly creates somebody else's obligation.
Your SEIS and EIS round can manufacture new PSCs. Anyone who ends up holding more than 25% of the shares or the voting rights becomes a person with significant control. On a small seed round that is not exotic — it is what happens when an angel takes a meaningful stake in a company with a short cap table. That investor now carries a verification duty timed to their birth month, they are unlikely to know it, and it is your company's register that shows the gap.
A fund on your register is a different animal. Where the PSC is a company rather than a person — a VC fund, a holding company, a corporate investor — verification for the officers of corporate PSCs has not started yet. Companies House has said it will introduce it later, along with verification for people who file documents and for corporate directors. So a round can leave you with two classes of PSC on one register, one with a live duty and one waiting for a rule that has not arrived. Do not assume the quiet one is compliant. Assume it is next.
And the timing is the real risk. Due diligence reads your filing history. A confirmation statement that bounced, or one filed late because a co-founder was travelling and had not verified, is not a catastrophe on its own — but it is an unforced signal of a company that does not have its house in order, discovered at the exact moment you are asking somebody to trust you with their money.
What is coming next
Two further changes are worth planning around rather than reacting to.
Verification will be extended to people who file documents at Companies House, to corporate directors, to corporate members of LLPs and to the officers of corporate PSCs. Dates have not been fixed for all of these.
Separately, filing on a company's behalf will eventually be restricted to firms registered as authorised corporate service providers — no earlier than November 2027, with at least six months' notice before it takes effect. If your accountant files for you, that is their problem to solve rather than yours, but it is a fair question to ask them now.
The short version
Verification is free, it takes minutes, and it is nobody's idea of interesting work. It is also now the thing standing between your company and a confirmation statement that Companies House will accept. The companies that get caught by it will not be the ones that considered it and decided to wait — they will be the ones that never realised a duty had attached to somebody who is not in the building.
If we file your confirmation statement, we track this as part of the job and chase the codes before the filing date rather than after it. If we don't, do the five-minute check anyway.
