Confirming identity verification to Companies House as a solicitor

Abolition of internal registers

These changes include abolishing internal registers of:

• directors kept by companies
• members kept by LLPs, and
• persons with significant control (PSCs) kept by companies and LLPs

The abolition of these registers took effect from 18 November 2025.

Identity verification

ECCTA 2023 also reforms the requirements to notify the registrar in respect of certain persons connected with a company or LLP.

Where relevant, the notification must (or, in some cases, may) include a statement that the individual’s identity has been verified (defined by section 1110A CA 2006).

These confirmations are required from 18 November 2025 and coincide with the commencement of mandatory identity verification (IDV).

For example, in relation to companies:

• section 12(2A) requires a statement of proposed officers on incorporation to state that the identity of each initial director who is an individual has been verified, and
• section 167G(3)(c) requires notice of the appointment of an individual as a director to state that the individual’s identity has been verified

In relation to LLPs:

• section 2(2)(ea) LLPA 2000 requires an incorporation document to state that the identity of each initial member who is an individual has been verified, and
• section 167G(4)(c) CA 2006 (as applied to the Limited Liability Partnerships (Applications of Companies Act 2006) Regulations 2009) requires notice of the admission of an individual as a member to state that the individual’s identity has been verified

In relation to both companies and LLPs:

• section 12B(2) permits a statement of initial significant control to state that the identity of each initial registrable person has been verified
• section 790LB(1) permits notice of an individual becoming a registrable person to state that the individual’s identity has been verified, and
• other notifications containing similar statements include those required by sections 790LM(2) and 790LN(2)

From 18 November 2025, similar requirements apply in relation to an individual listed as a director of an overseas company registered at Companies House (because it has a UK establishment).

See section 1048B CA 2006 and regulation 6A of the Overseas Companies Regulations 2009, as inserted by regulation 4 of the Companies Authorised to Register, Unregistered Companies and Overseas Companies (Application of Company Law) Regulations 2025.

From a date yet to be specified, similar confirmations will apply in relation to:

• a “relevant officer” of a registrable relevant legal entity (sections 790LB(2), 790LO(2) and 790LP(2))
• the “registered officer” of the general partner of a limited partnership (section 8A(1F) Limited Partnerships Act 1907)

Ask for confirmation of IDV

You might also wish to ask for specific confirmation from the individual (or someone on their behalf) that their identity has been verified.

This will normally be an unintrusive and innocuous step, and it may help to engage the principles set out in explanatory note 519.

Ask for the name used to complete IDV

The notification to Companies House will ask whether the name provided for the individual in the notification matches their verified name (the name under which they completed IDV).

If it does not, ask for a reason for the name difference.

Where the names do not match, Companies House may raise requisitions on the notification.

You may therefore want to ask for the name under which the individual completed IDV.

If the names do not match, you may want to seek clarification.

Other steps to consider

You will need to consider what other steps, if any, are warranted.

This will depend on the degree of confidence you have in the information provided to you and the source of that information.

You may reasonably conclude that no additional steps are required, depending on the context.

There is currently no way to independently cross-check a personal code against an individual’s name (or any other personal details, such as an address or a date of birth).

You may wish to consider what other extrinsic evidence you can look at.

This will depend on whether the individual’s details are already registered at Companies House: for example, because the individual is already a director, LLP member or registrable person.

If the individual’s details are registered

When an individual’s details are registered at Companies House and the individual has completed IDV, the registrar is under a duty to annotate the register to reflect this.

(See regulations 2 and 3 Companies and Limited Liability Partnerships (Annotations, Application and Modification of Company Law and Consequential Amendments) Regulations 2025).

You can check the individual’s entry at Companies House to see whether an annotation has been made.

In checking the register, you may wish to bear in mind the following considerations.

In our view, if information available at Companies House is adequate to identify the individual and confirms that the individual’s identity has been verified, this provides sufficient comfort to deliver an IDV confirmation.

Names of relevant entities

A search of an individual’s name at Companies House will reveal any instances where the individual is a director of a company or a designated member of an LLP.

This search will not, however, reveal any instances where the individual is a regular member of an LLP or a registrable person.

If these are the only positions the individual occupies, you could search the name of any relevant entity instead.

You may wish to ask for the names of any entities of which the individual is a director, LLP member or registrable person to be able to conduct searches.

Confusion with other persons

There may be more than one person registered at Companies House with the individual’s name, particularly if the individual has a commonly occurring name (such as “David Smith”).

You can cross-check the individual’s name against other information registered in the relevant entry, such as:

• any middle name(s)
• date of birth (noting that only the month and year will be displayed)
• address (noting that, in most cases, an individual’s residential address is not displayed on the public register)
• nationality
• occupation
• country of residence
• any other entities of which the individual is a director, member or registrable PSC

Other known names

An individual may be registered at Companies House under a different name from that given in the IDV confirmation notification.

You might consider carrying out searches on a reasonable range of known names used by the individual.

Multiple registrations at Companies House

An individual may have multiple registrations at Companies House, even under the same name and with identical (or substantially similar) details.

You may wish to check multiple entries.

If the individual’s details are not registered

The steps above will not be possible if the individual’s details are not registered at Companies House.

You might consider what other external evidence you can obtain, bearing in mind the different processes for doing so.

It is for you to decide what evidence is most appropriate in the circumstances. However:

• if the individual completed IDV directly online with Companies House, you could ask the individual to provide a copy of their code confirmation page, and
• if the individual completed IDV through an ACSP, you could ask the individual to provide a copy of the email from Companies House containing their personal code

Ideally, the evidence should display both the personal code and other information sufficient to associate the code with the individual (for example, their name or email address).

In some cases, an individual’s details might not be registered at Companies House and they might not be able to provide extrinsic evidence of their personal code.

This could happen if, for example:

• the individual’s identity was verified by the registrar, but they are unable to gain access to their Companies House online account (for example, because they do not have their log-in credentials) and have not made a copy of their code confirmation page, or
• their identity was verified by an ACSP, but they cannot obtain the email containing their personal code (for example, because they no longer have access to the relevant email account or the email has been irretrievably deleted)

In these cases, you may consider asking questions to make sure they understand the context and reasons why the individual cannot provide extrinsic evidence.

You should reach a reasoned conclusion based on the circumstances.

You could also consider asking the individual to request a new personal code from Companies House.

Differences in name given and name registered

In all cases, be mindful that the individual’s name given in the notification containing the IDV confirmation may differ from the name (or names) under which they are already registered at Companies House or under which they completed IDV.

Legitimate reasons where this could happen include:

• the individual has legally changed their name since completing IDV or being registered at Companies House (although any change in the name of a director, LLP member or registrable person must be notified to Companies House)
• the individual legitimately uses a former name for work purposes (for example, a pre-marital or pre-civil partnership name) or a separate professional name
• the individual commonly goes by a middle name, rather than their first name
• the individual commonly goes by a nickname (such as “Jess” instead of “Jessica”)
• the individual’s name has been translated from another language (for example, “William” instead of “Guillermo”) or transliterated from another script (which can often generate multiple variations in the Latin alphabet), or
• the individual uses a separate “Western name” or “European name” in certain contexts

If conducting searches, you might consider searching under any variations and aliases provided by the individual (or on their behalf).

In our view, you are not expected to take it upon yourself to identify and search against names, or variations of names, that have not been specifically provided to you.

Identity reverification

The registrar can, by notice, require an individual to reverify their identity in limited circumstances.

If the individual does not reverify by the deadline stated in the notice:

• they cease to be an individual whose identity is verified (regulation 14 IDV Regulations), and
• their personal code ceases to be valid (regulation 24(1))

If the individual’s identity is successfully reverified, the registrar will allocate a new personal code (regulation 25).

You should bear this in mind when giving an IDV confirmation in relation to an individual who has completed reverification.

Make sure you obtain and validate their correct, up-to-date personal code.