▸ RegulatoryThe Economic Crime and Corporate Transparency Act 2023 mandates identity verification for all UK directors and PSCs by September 2026. Here is what foreign nationals must do.
The Economic Crime and Corporate Transparency Act 2023 (ECCT Act) introduced the most significant structural change to UK company registration in a generation. One of its central pillars — mandatory identity verification for company officers and persons with significant control — moves from optional pilot to compulsory requirement by September 2026. For foreign nationals who hold directorships or PSC status in UK private limited companies, the window to comply is narrowing.
Under the ECCT Act and the Companies House identity verification framework (operationalised through secondary legislation published in late 2025), the following individuals must verify their identity:
Identity verification is a one-time process tied to a Companies House personal account, but it must be completed and linked to each relevant company filing. Companies House confirmed in its February 2026 implementation update that unapplied-for verifications after the deadline will result in the officer's details being flagged on the public register as unverified — a disclosure that increasingly appears in counterparty due diligence checks.
UK residents and many foreign nationals with compatible document types can verify directly through the Companies House online service using a Government Gateway account. Accepted documents include:
The process is digital-only. Companies House uses a certified third-party identity verification provider to check document authenticity and perform a liveness check (a brief facial recognition step). This takes approximately 15–20 minutes if your documents are in order.
The limitation for foreign directors: non-EEA national identity documents are not currently in scope for the direct digital route. If your primary ID is a non-EEA passport that fails chip verification, or if you do not hold a UK driving licence, direct verification can fail at the document check stage.
ACSPs are firms registered with Companies House to perform identity verification on behalf of clients and submit a confirmation to the register. An ACSP carries out the verification to Anti-Money Laundering (AML) standards — the same standards applied to regulated professionals under the Money Laundering Regulations 2017 — and submits a verified identity certificate to Companies House on the individual's behalf.
This route is the correct path for:
INNOVA CG is a registered ACSP with Companies House. We can complete identity verification for foreign directors and PSCs as part of our UK company formation and maintenance services, or as a standalone engagement.
Companies House has been explicit that identity verification is not optional after the mandatory implementation date. The consequences flow in two directions:
For the individual: From the implementation date, an individual who has not verified their identity cannot be appointed as a director or register as a PSC. Existing unverified officers will be flagged on the public register, which does not automatically remove them from office but does create disclosure issues.
For the company: The company commits a criminal offence if it knowingly permits an unverified person to act as a director after the deadline. The ECCT Act introduced new civil penalties (up to £10,000 in the most serious cases) alongside the existing criminal regime under the Companies Act 2006.
In practice, the immediate operational impact will be felt by foreign-owned companies when they need to file confirmation statements, change officers, or make other filings — Companies House's online filing portal will require verified identity before accepting submissions from unverified individuals.
Audit your Companies House appointments. Pull a current list of all UK companies in which you are named as director or PSC. Use Companies House WebFiling to confirm your current registered details are correct — verifying against incorrect details will trigger a flag.
Determine your verification route. If you hold an EEA passport with a functioning chip, attempt the direct Government Gateway route first. If you expect friction — non-EEA documents, chip failures, address mismatches — engage an ACSP.
Complete verification before mid-July 2026. The September 2026 deadline is the legal cutoff, but Companies House has consistently underestimated processing volumes at previous regulatory deadlines (including the PSC register introduction in 2016 and the new authentication code regime in 2021). Complete early.
Update your Companies House account. Once verified, log into your Companies House personal account and confirm the verification is linked to every company in which you hold a relevant role.
Brief co-directors and co-shareholders. If you are the compliance lead for a company with multiple foreign directors or PSCs, each individual must verify independently. Corporate PSCs (e.g., a BVI holding company owning shares) may face additional requirements under the register of overseas entities regime introduced by the Economic Crime (Transparency and Enforcement) Act 2022.
From the implementation date, identity verification is a prerequisite for new director appointments and PSC registrations — not a grace-period obligation. If you are planning to restructure a UK company's leadership, appoint a new director, or add a new shareholder above the 25% threshold, factor verification lead time into your planning. An unverified appointment cannot be completed through Companies House filing systems.
See our UK incorporation services and UK restructuring practice for related guidance on maintaining compliant UK corporate structures as a foreign national.
INNOVA CG's UK corporate team provides ACSP-registered identity verification services, Companies House filing management, and ongoing UK company secretarial support. This memo does not constitute legal advice.
This material is for general information only and does not constitute legal or tax advice. Accurate as of the publication date.
