One director holds eight appointments. A founder is also a person with significant control. Another PSC lives abroad, uses a different name on an old company record and has never shared a personal code with the secretarial team. Each individual may verify only once, but every role still has to be connected correctly and on time. Since 18 November 2025, identity verification has moved from a future reform to an operating requirement for new directors and PSCs, while existing roles pass through a twelve-month transition. The commercial opportunity is not to sell a generic “Companies House compliance” promise. It is to sell a portfolio readiness review that maps people, roles, companies, due dates, record mismatches, verification routes and filing responsibility. This reading shows how legal, accountancy and company-secretarial specialists can turn that map into a useful first engagement and recurring governance without promising that Companies House will accept a filing or that identity checks resolve wider ownership risk.
What changed when mandatory identity verification began?
Mandatory identity verification began on 18 November 2025 for new company incorporations, new director appointments and new PSCs. Existing directors and PSCs entered a phased transition tied to role-specific dates, so the practical question is no longer whether verification will happen but when each role must be connected.
Companies House expects millions of individuals to pass through the process by the end of the transition period in November 2026. An existing director normally provides a personal code through the company’s next confirmation statement. A PSC has a 14-day submission period determined by whether the person is also a director and by the relevant company or birth-month timing. Limited partnerships, corporate directors, corporate LLP members and officers of corporate PSCs sit in later implementation phases and must not be assigned an invented deadline.
Why is a personal code not the end of the job?
A personal code confirms that an identity was verified; it does not automatically connect every appointment or PSC role, correct mismatched register data, authorise a firm to act, or prove the entire beneficial-ownership chain. The code must be used safely in the correct company action.
The same code can support several roles, which makes portfolio control essential. If a date of birth or name does not match the register, the connection may fail until the record is corrected. Teams should never store codes in an unprotected communal spreadsheet or assume that receipt of a code means the next confirmation statement is ready.
What should a portfolio readiness review contain?
A portfolio readiness review should contain the legal entities in scope, every director and PSC role, verification status, personal-code custody, role deadline, confirmation-statement date, register mismatch, chosen route, filing owner and unresolved dependency. It should end with a dated action queue, not a general reform briefing.
The review should be limited to a defined group or portfolio and clearly separate identity verification from anti-money-laundering checks, sanctions screening, beneficial-ownership advice and transaction due diligence.
| Portfolio field | Decision supported | Common failure |
|---|---|---|
| Person and aliases | Which records belong together? | Duplicate identity assumed |
| Company and role | Where must status be connected? | Appointment omitted |
| Verification route | One Login, Post Office or ACSP? | Route not feasible for person |
| Code custody and consent | Who may use the code? | Shared insecurely |
| Due date and filing event | When is action required? | Confirmation statement treated as universal |
| Register mismatch | What must be corrected first? | Connection attempted repeatedly |
| Responsible operator | Who completes and checks the action? | Adviser and client both assume the other acts |
When should a client use One Login, the Post Office or an ACSP?
The route should reflect the person’s documents, digital access, location, support needs and timing. GOV.UK One Login is a direct route; Post Office support can help eligible users; an Authorised Corporate Service Provider can verify a client only if it meets the Companies House standard and its own legal obligations.
Route choice is an operating decision, not a hierarchy of trust. An overseas director may need different preparation from a UK founder with standard documents. The adviser should confirm the current route rules and handle personal data proportionately. Verification evidence submitted to the official service is not simply content for the public register, but the verification status and associated statements affect visible company records.
- id6a76376911a53f0001fa327f
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- rawtype: route-decision-matrix title: Match the person to a feasible verification route columns: - Direct online route - Supported in-person route - ACSP-assisted route rows: - Document availability - Digital access - Geography and timing - Data-handling requirement - Adviser responsibility
- rowsDocument availability · Digital access · Geography and timing · Data-handling requirement · Adviser responsibility
- columnsDirect online route · Supported in-person route · ACSP-assisted route
What changes when the adviser becomes an ACSP?
An ACSP must be supervised by a UK anti-money-laundering supervisory body, register with Companies House, meet the official identity-verification standard, keep required records for seven years and respond to information requests. Registration creates accountable operations; it is not a marketing badge or blanket filing authority.
Only agents intending to verify clients currently need ACSP registration for that activity. The requirement for all third-party presenters to be registered was postponed to no earlier than November 2026. That distinction matters: firms should not announce a filing deadline that Companies House has explicitly rescheduled. ACSP account access must be assigned to individual users; shared One Login credentials undermine control.
- Confirm eligible AML supervision
- Register the agent and accountable users
- Apply the Companies House identity standard
- Record evidence and verification decision
- Notify Companies House correctly
- Retain records for seven years and answer requests
Which client events create an urgent buying decision?
A new incorporation, director appointment, upcoming confirmation statement, acquisition, group restructure, financing, dormant-company review, overseas officer change or failed identity connection can create an urgent buying event. Outreach should name the affected workflow, not imply that the company is already in breach.
Company-secretarial firms can identify dates in portfolios they already administer. Legal and accounting partners can introduce a review during transactions, annual accounts or governance changes. Search content can answer role-specific questions, while selected outreach can reference a published appointment or corporate event. The offer remains a bounded readiness review; a fear-led broadcast about penalties weakens trust.
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- rawtype: portfolio-priority-grid title: Prioritise by deadline and unresolved dependency axes: x: Time until company action y: Number and severity of unresolved dependencies quadrants: - Monitor - Prepare evidence - Correct register data - Escalate now
- axes
- quadrantsMonitor · Prepare evidence · Correct register data · Escalate now
How should the service continue after the transition year?
The recurring service should govern new appointments, departures, PSC changes, personal-code custody, register corrections, confirmation statements, ACSP records and official implementation updates. Its value is a portfolio that can explain what changed, who acted and what remains due—not an annual verification reminder.
Presenter measures are scheduled no earlier than November 2026, and limited-partnership and corporate-role reforms continue on separate timetables. A versioned rules register prevents a team from applying a future measure too early or missing its eventual commencement. The service can also sample completed actions and expired client authority so operational drift is visible.
Which official sources bound the advice?
The Economic Crime and Corporate Transparency Act 2023 provides the statutory reform, while Companies House guidance supplies the current implementation dates, role rules, personal-code process, ACSP standard and enforcement approach. Advisers must recheck those operational pages before assigning a deadline or filing action.
This reading uses Companies House’s transition plan updated in January 2026, identity-verification collection, personal-code guidance updated in June 2026, and ACSP guidance updated in June 2026. It promises no acceptance, deadline extension, verified beneficial ownership, transaction completion or legal outcome.
Could GetFishNet build a tailored acquisition route for your company-secretarial expertise?
GetFishNet can test whether your expertise, portfolio access, first readiness review and delivery controls form a credible acquisition opportunity. The free eligibility test examines present acquisition pain points and development synergies without promising verification, filings, clients or revenue.
If your team can turn scattered roles and deadlines into one controlled action queue, we can design a tailored multichannel route around the company events that make that work timely.
The eligibility report dates and quantifies it, then tests whether it deserves action.
Reading the diagram. A disease contact only progresses after proof of origin, qualification of the relationship and control of the product concerned.
Text alternative. Telephone, prescriber or incoming request follow different proofs; missing consent causes documented exit.
How can the testing cycle reach a stable operating rhythm?
Relative benchmarks: D00 sets the rules of origin and termination of contact, D14 closes the preparation, W03 to W06 tests the scripts, consents, relationships of more than thirty-six months and ceilings per product, W07 to W08 arbitrator, then M03 stabilizes documented paths. Variances are recorded before any budget extension.
Gantt chart for the testing cycle — NON-EXHAUSTIVE DEMONSTRATION
Reading the diagram. The foundation secures the right to contact; exploration then measures the quality of requests before any channel stabilization.
Textual alternative. D00 sets consent, D14 audits scripts, W03–W06 tests provenance, W07–W08 cuts discrepancies, M03 maintains compliance.
What financial potential does the model make visible?
Model: 132 qualified conversations, 44 reviews and 26 new customers. Weighted average: 1 527 CHF; monthly total: 39 700 CHF. The projection concerns acquisitions agreed and allocated, without using the ceilings as margin or portfolio value. No national denominator is applied.
Breakdown of acquisitions — NON-EXHAUSTIVE DEMONSTRATION
The chart counts customers, not percentage points.
Reading the diagram. 26 acquisitions represent subscriptions preceded by a controlled origin and relationship; the size of a share does not prejudge either the documentary quality or the maintained value.
Text alternative. The circle distributes customers obtained after verifiable consent, never people simply called. Total: 26 customers, reread with the value specific to each channel.
How do customers, average monthly revenue, and recurring revenue correlate by channel?
| Channel explored | Customers | Average monthly revenue per customer | Monthly Recurring Channel Revenue |
|---|---|---|---|
| Natural and paid referencing | 4 | 1 300 CHF | 5 200 CHF |
| Telephone outreach | 3 | 1 600 CHF | 4 800 CHF |
| Voicemails | 2 | 900 CHF | 1 800 CHF |
| Email Campaigns | 4 | 1 200 CHF | 4 800 CHF |
| Social networks | 3 | 1 400 CHF | 4 200 CHF |
| Partners and prescribers | 3 | 2 000 CHF | 6 000 CHF |
| Events and webinars | 2 | 1 700 CHF | 3 400 CHF |
| Advertising retargeting | 1 | 1 100 CHF | 1 100 CHF |
| Strategic accounts and outbound outreach | 2 | 2 300 CHF | 4 600 CHF |
| Content and press relations | 2 | 1 900 CHF | 3 800 CHF |
| Total / weighted average | 26 | 1 527 CHF | 39 700 CHF |
The value is read again with the product, the applicable ceiling and the cost of controlling the provenance. The product customers × average income totals 39 700 CHF without promising performance.
Monthly recurring revenue by channel — NON-EXHAUSTIVE DEMONSTRATION
Reading the diagram. Compliant disease contacts, their converted volumes and the corresponding monthly income recompose 39 700 CHF without a value outside the table.
Alternative text. Each height associates an authorized channel, actual assigned customers, and the value specific to their product. Their addition exactly equals monthly 39 700 CHF.
How should acquisition cost be assessed before recurring revenue is scaled?
Arbitration adds proof of consent, script control, relationship data, call supervision and refusal handling and reports the charge to assigned customers. It compares legal origin, product concerned, ceiling, full cost, expected termination and service capacity then reduces any channel that weakens the proof.
Funnel to Retained Monthly Recurring Revenue — NON-EXHAUSTIVE DEMONSTRATION
Reading the diagram. disease contacts whose origin is demonstrated produce raw 39 700 CHF, then 34 142 CHF after maintaining at 86 %.
Text alternative. 132 conversations become 44 journals and 26 clients for disease contacts whose provenance is demonstrated. 39 700 CHF weighted to 86 % gives 34 142 CHF.
Financial limit. The 70 francs and the sixteen bonuses limit the remuneration; they give neither margin, nor number of contracts, nor maintenance. The 34 142 CHF remains a hypothesis, without reference value or forecast.
Which sources and related readings deepen this analysis?
Text references: Federal Office of Public Health, decision and rules applicable to intermediaries; monitoring activity report. The federal office describes ceilings and outreach, while consent and history remain evidence specific to the file. The addresses remain in the internal source register. Each topic retains a clear documentary boundary.
The ISA 2024 processes the status. The ICA 2022 processes the contract trace. The nLPD 2023 shows another prequalification of the contact and data.
CORRELATED READINGS — DYNAMIC MODULE
The thematic map will link rules 2024 of health insurance intermediaries to ISA for status, ICA for contract and nLPD for legality of contact data. The links remain governed without implying equivalence.
- See the insurance & brokerage market
- Explore all market readings
- Test the eligibility of your own window
The September deadline has passed; each origin of contact must always be able to be explained The report isolates the proof and the next action without reopening the 2024 rules of health insurance intermediaries.
The topic is broken down into entities, attributes, evidence, channels, costs and decision points. Institutions are cited in the text; no external resource interrupts the reading path.