The Economic Crime (Transparency and Enforcement) Act 2022: Companies House identification verification timetable announced

Following on from our previous article on The Economic Crime (Transparency and Enforcement) Act 2022 (ECCTA), companies must now prepare themselves ahead of ECCTA’s new implementation deadlines for its new-and-improved identity verification procedure.

These new verifications are aimed at improving the accuracy and transparency of information at Companies House and reducing fraudulent and anonymous filings.

Timetable (as at 25 February 2025):

• From Spring 2025:

• • Authorised Corporate Service Providers (ACSPs) can seek authorisation to perform identity verification services.
  • TSP are taking steps to register as an ACSP in order to continue to making filings at Companies House on behalf of our clients.
• From 25 March 2025: 
  • Voluntary identity verification begins using Companies House’s new online platform, the GOV.UK One Login, or an ACSP.
  • There will be three ways to prove identity either using the GOV.UK ID Check app; by answering security questions online; or taking documents to a Post Office with voluntary notification.
• By Summer 2025:
  • Companies House will allow access on request to certain trust information on the Register of Overseas Entities.
  • The Registrar can receive and assess applications from individuals seeking to suppress their day of birth for documents registered before 10 March 2015, signature, business occupation, and residential address in most other instances.
• By Autumn 2025:
  • Mandatory identity verification will be introduced for new incorporations, directors, Persons of Significant Control (PSCs) and Registered Legal Entities (RLEs).
  • There will be a 12-month transition for existing directors, PSCs and RLEs. Details will need to be provided when annual confirmation statements are filed.
• By Spring 2026:
  • Mandatory identity verification begins for all document presenters.
  • Any third party agents presenting documents will be required to be registered as ACSPs.

The consequences of non-compliance with the identity verification requirements will depend on the circumstances. However, an individual who is required to verify their identity, and fails to comply, could be subject to the following:

• criminal proceedings (fines)
• civil penalties
• rejection of incorporations/registration of a new companies
• restrictions on being unable to file statutory filings
• the public register being annotated to show the individual’s status as ‘unverified’
• unverified directors being prohibited from acting as a director

There will also be a new offence which applies to the director or equivalent of an ACSP, of failure to notify the Registrar of changes to their supervisory body/bodies within a period of 14 days following the change.

Practical recommendations:

1. Review the company’s group structure – carry out an audit to establish who in your business will need to be verified.
2. Check all contact details – make sure you have up-to-date contact details for all directors and PSCs (particularly for PSCs who are based overseas who are therefore harder to contact)
3. Check all ID documents on file – establish whether your directors and PSCs have the necessary and up-to-date ID documentation, and resolve any outstanding issues now.
4. Review your internal processes – make sure your internal processes accommodate the new threshold for identification verification.

If you would like any further information or assistance in relation to the above mater, please contact co-author, Caroline Nicholls or visit TSP’s Corporate and Commercial Team page to see what services we offer.