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
- chartTypebar
- isModelledDatatrue
- 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.
Editorial provenance
Sources used
- UK Legislation, Economic Crime and Corporate Transparency Act 2023
- Companies House, Economic Crime and Corporate Transparency Act: outline transition plan
- Companies House, When you need to verify your identity for Companies House
- Companies House, Companies House personal codes for identity verification
- Companies House, Being an Authorised Corporate Service Provider
- Companies House, How to meet Companies House identity verification standard
- Companies House, Approach to non-compliance with mandatory identity verification
The eligibility report dates and quantifies it, then tests whether it deserves action.
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.