Companies House began rolling out mandatory identity verification for directors and persons with significant control on 18 November 2025, with a twelve month transition period running through to 17 November 2026, after which active compliance and enforcement activity is expected to begin against anyone who has not completed the process. Roughly two thirds of the way through that transition period, Companies House's own published management information for the second quarter of 2026 shows a compliance picture that should concern any firm holding a portfolio of corporate clients: by the end of June, only 55% of directors, 50% of LLP members and 42% of persons with significant control had informed Companies House of their verified identity.
Those are not small minorities slipping through the cracks. They are close to, or in the case of PSCs, a clear majority of the people the regime is designed to capture, still unverified with less than five months left before enforcement is expected to start in earnest. For an accounting practice, this is not an abstract policy statistic. It is a direct, quantifiable measure of how much filing risk currently sits inside its own client bank.
It is also worth noting what the trajectory of these figures suggests rather than treating them as a single static snapshot. A verification rate sitting around half of the affected population roughly two thirds of the way through a twelve month transition period implies that a meaningful share of directors and PSCs are waiting until closer to the deadline, whether out of genuine unfamiliarity with the requirement, simple procrastination, or an assumption that the deadline will slip. None of those explanations are reassuring for a firm relying on those individuals to be verified in time for a filing that cannot wait.
What actually happens to an unverified company
The consequence of a director or PSC failing to verify their identity is not a warning letter that can be quietly ignored. Once enforcement begins, a company with unverified officers or PSCs faces real, practical obstacles: the company cannot file certain documents at Companies House, the public register is annotated to flag the non-compliance, and failure to verify is itself a criminal offence that can attract financial penalties. For a firm acting for that company, an unverified director does not just sit as a compliance footnote. It becomes a filing that will not go through, at exactly the moment a confirmation statement or accounts deadline is due.
The annotation on the public register is worth dwelling on, because it is visible to anyone who looks the company up, including lenders, landlords, suppliers running due diligence, and prospective clients or investors. A firm that lets this slide for a client is not just risking an administrative inconvenience, it is risking a visible, public mark against that client's corporate record that has nothing to do with the underlying health of the business and everything to do with a piece of paperwork nobody completed.
- By end of June 2026: 55% of directors had informed Companies House of their verified identity
- By end of June 2026: 50% of LLP members had informed Companies House of their verified identity
- By end of June 2026: 42% of persons with significant control had informed Companies House of their verified identity
- Transition period: 18 November 2025 to 17 November 2026
- Consequence of non-verification once enforcement begins: certain filings blocked, the public register annotated, and an offence under the Act with potential financial penalties
Why PSCs are lagging furthest behind
The gap between the 55% verification rate for directors and the 42% rate for PSCs is not surprising once the two groups are considered separately. Directors are, almost by definition, the people actively running the day to day administration of a company, receiving Companies House correspondence, and dealing with an accountant or company secretary who is likely to flag the requirement directly to them. Persons with significant control are frequently a step removed from that operational relationship: a majority shareholder who is not a director, a parent company officer, a family member with a controlling stake who takes no active role in the business. These are exactly the people least likely to see a Companies House reminder land in their inbox, and least likely to have a working relationship with the firm that could otherwise chase them.
For firms, this means the highest-risk segment of a client portfolio is not necessarily the client company itself, it is the individual PSC who sits one or two steps removed from the firm's normal point of contact. A director who has verified their own identity gives a false sense of security about the company's overall compliance position if a controlling shareholder behind that director has not done the same.
Corporate PSCs add a further layer of complexity that the headline statistics do not fully capture. Where the person with significant control of a client company is itself another company, rather than an individual, the verification chain has to reach through to the individuals who ultimately control that corporate PSC. Firms acting for clients with layered ownership structures, a UK trading company owned by a holding company, owned in turn by an individual or a small group of individuals, need to map that chain explicitly rather than assuming the first name that appears on the PSC register is the end of the story.
Running a portfolio audit before enforcement starts
The practical response is a straightforward audit exercise, and the sooner it is run the more useful it is. For every corporate client, list the current directors and any registered PSCs, and check each one's verification status. This information is increasingly visible through the Companies House service directly, and firms acting as agents can build this check into a routine review rather than a one-off exercise.
A firm running this audit for the first time is often surprised by how much its own internal records have drifted from the actual current position at Companies House. Directors who resigned years ago but were never formally removed from a firm's working notes, PSCs who were identified at onboarding but never revisited as ownership changed, and companies where the firm's point of contact is a director who is not actually the individual with significant control, all surface during a proper audit in a way they rarely do during routine day to day client work.
Once the list exists, prioritise by risk rather than working through it alphabetically. Clients with an imminent confirmation statement or accounts filing deadline should be at the top, because those are the filings most likely to be blocked if verification has not happened in time. Clients with PSCs who are not directors and therefore less likely to have already engaged with the process should be next, because they represent the compliance gap the data suggests is widest. Everyone else can follow in a more routine cadence.
The client conversation, framed the right way
Directors and PSCs who have not yet verified their identity are not, in most cases, deliberately ignoring the requirement. Many simply have not registered that it applies to them personally, particularly PSCs who do not think of themselves as engaged in the company's administration at all. The most effective client outreach treats this as a short, specific, personal task rather than a general compliance reminder buried in a longer newsletter: tell the individual directly what they need to do, how long it takes through GOV.UK One Login, and what happens to the company's filings if they do not.
It is worth being direct about consequences without being alarmist. A calm message along the lines of "this takes most people under fifteen minutes to complete online, and if it is not done before enforcement begins your company will not be able to file certain documents" tends to produce a better response rate than a vague reminder that the requirement exists. For PSCs who are genuinely hard to reach, routing the request through the director or company contact who already has an active relationship with the firm, and asking them to personally chase the PSC, is often more effective than a firm attempting to contact an individual it has no existing relationship with directly.
Cross-referencing against existing AML client files
Many firms already hold a reasonable amount of identity information on their corporate clients through ordinary client due diligence carried out under Money Laundering Regulations 2017, and it is tempting to assume this existing paperwork means the Companies House verification requirement is largely already satisfied in substance, even if not formally logged with Companies House itself. That assumption is worth treating carefully. The two regimes serve different purposes and are checked by different bodies, and a passport copy sitting in a firm's AML file from three years ago does not automatically translate into a completed Companies House identity verification against that individual's record.
What the existing AML files are genuinely useful for is triage. A firm that already holds recent, good-quality identity evidence for a director or PSC has a considerably easier job pointing that individual towards the Companies House verification route than a firm starting from nothing, because the conversation becomes "please complete this specific online step" rather than "please send us your documents from scratch". Using the AML file as the starting point for outreach, rather than assuming it already discharges the obligation, is the more useful way to think about the overlap between the two systems.
The overlap with becoming an ACSP
This sits alongside, and interacts with, the separate requirement for firms to register as an Authorised Corporate Service Provider before they can continue filing on clients' behalf. A firm that has not yet registered as an ACSP will, once the filing restriction takes effect, be doubly exposed: unable to file for clients at all in its own right, and simultaneously trying to chase directors and PSCs who have not verified their own identity. Firms that treat these as two separate projects running on two separate timelines are more likely to be caught out by the accumulation of both deadlines landing in the same window at the end of 2026 than firms that plan for them together as a single corporate compliance programme.
What good looks like heading into November
A firm in a strong position by November 2026 will be able to say, with confidence and evidence, that every director and PSC across its active corporate client base has either verified their identity or has a specific, tracked plan in place to do so before the transition period ends. It will have completed its own ACSP registration well ahead of any restriction taking effect. And it will have communicated clearly with clients about what verification actually requires of them, rather than assuming a single email months ago was sufficient.
The uncomfortable reality suggested by the current statistics is that most firms are not yet in that position, and neither are most of their clients. A verification rate sitting around half of the affected population, with less than five months of transition period remaining, is not a situation that resolves itself through client goodwill and general awareness. It resolves through firms actively identifying who is exposed and actively chasing them, which is exactly the kind of work that benefits from being tracked rather than remembered.
There is a reasonable argument that firms have more to lose from this than the individuals who simply have not verified yet. An unverified PSC personally faces a specific, defined offence and a personal inconvenience. A firm acting for a portfolio of corporate clients where a meaningful proportion turn out to be unverified in November faces a wave of blocked filings landing across its client base simultaneously, at the exact moment its own capacity is already stretched by whatever else the autumn compliance calendar brings. The asymmetry of exposure is worth using as the motivating argument internally when this work competes for priority against other client deadlines.
Turning the audit into an ongoing workflow
The firms handling this well are not treating it as a single sweep through the client list followed by relief once the emails have gone out. Identity verification status, like any other compliance deadline, needs to sit somewhere visible and be revisited as new directors are appointed or PSCs change, because the obligation does not end when the transition period does, it becomes an ongoing part of onboarding any new corporate client or officer from that point forward. A Smart Board built around corporate compliance, with a card per client tracking verification status for every director and PSC, deadline tracking against confirmation statement and accounts dates, and a Client Hub used to request and store the confirmation once it has happened, keeps this visible in the same place the rest of a client's engagement already lives, rather than as a separate spreadsheet that goes stale the moment it is finished.
