Companies House identity verification: which client file needs fixing first?

Identity verification at Companies House is no longer an abstract reform. Compulsory requirements began on 18 November 2025, and the twelve-month transition means directors and people with significant control can have different due dates across different company roles. For an accountancy firm, that creates a high-intent market—but only if the first offer fixes a real file rather than charging for access to a free government route. This reading shows how to prioritise affected clients, distinguish direct verification from an Authorised Corporate Service Provider service, and package a paid company-control review without inventing outcomes. The commercial value lies in reconciling identities, roles, deadlines, codes, permissions and evidence. The safest proposition gives the client a clear route to completion, records what the firm has and has not verified, and moves suitable companies into a controlled annual filing service. Strategic market analysis, not legal, anti-money-laundering or personal identity-verification advice.

Identity verification became compulsory for new directors and people with significant control from 18 November 2025, while existing directors entered a twelve-month transition linked to confirmation statements and PSCs received role-specific windows. Companies House estimated six to seven million people would need to verify by mid-November 2026.

One person may hold several roles and must connect a verified identity to each relevant record. The client problem is therefore not simply “get verified”. It is to identify every role, its due date, the correct personal code and the filing action that completes the connection.

Prioritise new appointments, existing directors approaching their next confirmation statement, PSCs inside their notified verification window and people with several company roles. The register’s due-date information—not a generic campaign date—should drive the sequence, because one individual’s roles may not share the same completion point.

Build a triage list from verified client data: company number, person, role, status, stated deadline, confirmation-statement date, contact owner and route chosen. Never expose personal codes in marketing systems. Missing or conflicting names, dates of birth, addresses or role records should trigger controlled remediation before a verification promise.

Direct Companies House verification through GOV.UK One Login is free. An ACSP can charge for a professional service that verifies identity to the Registrar’s standard, manages evidence and records, or coordinates complex company roles—but it should not imply that paying an agent is the only compliant route.

That distinction sharpens the offer. Straightforward clients may need a guided control review and then verify directly. Others may prefer an ACSP route or need help reconciling roles. The paid value is professional handling, evidence discipline and completion control, not artificial scarcity around a public service.

A defensible review matches the person’s current identity evidence to the Companies House record, company roles, email access, personal code, due dates and filing permissions. An ACSP that performs verification must also follow the Registrar’s verification standard and retain identity-check records for seven years.

Keep identity evidence out of ordinary CRM notes. Define restricted storage, access, retention, deletion and incident ownership before accepting documents. Companies House guidance also requires an authorised agent to remain supervised by a UK anti-money-laundering supervisory body and to report changes to its own registered information within fourteen days.

The best first purchase is a fixed-scope company-control review covering named entities and people. It ends with a role-and-deadline register, discrepancy list, verification-route decision and completion plan. It does not promise that every person can be verified or that every historic register issue can be solved inside one fee.

Quote by defined scope—companies, people and roles—not by fear. State which identity checks, filings or legal opinions are excluded. Set the price and turnaround only after checking staff authorisation, secure tooling and case complexity. A useful review creates a clean decision even when the answer is referral.

The personal code links a successfully verified identity to Companies House roles. It is sensitive operational data: the client must know where to find it, the firm must know when it may be used, and every connection needs a recorded completion state rather than an assumption that verification alone finished the task.

Use a status model: evidence requested, identity route chosen, verified, code received, role connected, exception, complete. Do not copy codes into campaign tools or shared spreadsheets. The acquisition hand-off should name who receives sensitive material and who closes each role.

A legitimate recurring service maintains the role register, confirmation-statement timetable, officer and PSC changes, filing evidence and escalation log. It earns renewal by keeping company records coherent as people and roles change—not by reselling a one-off identity check every year.

The agreement should define client notification duties, included filings, approval steps and urgent-change fees. Identity re-checking is not assumed. Sensitive data controls and ACSP obligations remain explicit. This turns a deadline project into company-secretarial governance without overstating what an accountant can decide.

Existing-client reactivation is strongest because the firm already knows the company relationship; search captures urgent verification intent; legal and formation-agent partnerships reach complex role changes; selected outbound can target multi-company directors. Every message should invite a role check, not declare that the recipient is non-compliant.

Measure completed reviews, resolved discrepancies and accepted annual-service proposals. Segment by observable company context, not protected or speculative personal traits. The useful campaign question is: “Can you evidence the verification and connection status of every director and PSC role?”

Use current Companies House rollout and identity-verification guidance, the ACSP operating guidance and the Economic Crime and Corporate Transparency Act 2023. These sources support role, route and transition claims; they do not support invented conversion rates, guaranteed completion or a claim that an agent route is mandatory for everyone.

Private source register:

• Companies House, Identity verification for Companies House.
• Companies House, Identity verification rollout from 18 November 2025.
• Companies House, Being an Authorised Corporate Service Provider.
• UK Parliament, Economic Crime and Corporate Transparency Act 2023.

Launch when the firm is properly authorised for every promised activity, has secure evidence handling, can distinguish direct and ACSP routes, and can deliver a role-level completion register. Publication and translation remain on hold until a human editorial reviewer approves the source claims, service boundary and conversion path.

Test the workflow on anonymised role patterns before promotion. Confirm that sales staff cannot see identity documents, that operations can report exceptions, and that the client understands a verified person may still have role-connection tasks. The premium position is calm completion control, not deadline theatre.

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