ECCTA 2023: identity verification – a how-to guide for directors and PSCs

One of the key reforms introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA) is the requirement for directors, PSCs and other people holding similar roles (LLP members for example) to verify their identify. This will be mandatory for new appointments from autumn 2025 and phased in for existing appointments from spring next year. However, from 8 April 2025, individuals can choose to voluntarily verify their identity with Companies House. Here’s what you need to know about the verification process and the documentation you will need.

Who needs to verify their identity?

Individuals that can and, in future will be required to, verify their identity include:

• New directors and people with significant control (PSCs)
• Existing directors and PSCs (and those holding similar roles such as LLP members)
• Relevant officers of RLEs (a new appointment at Companies House which is also required under ECCTA)
• Anyone filing documents at Companies House

Steps for verifying your identity

You can verify your identity yourself, using the GOV.UK One Login website, or you can engage an Authorised Corporate Service Provider (ACSP) which provides verification services (not all will do this).  Doing it yourself online will be free, and in most cases should be quick and easy and therefore the route we would usually recommend.

Verifying your ID yourself online

There are three ways you will be able to verify your identity yourself. Depending on the device you’re using and the type of ID you have, the options are:

1. Using the GOV.UK ID Check app
2. Answering security questions online
3. Face to face at a Post Office

 1. Using the GOV.UK ID Check app

Accepted types of photo ID

For this you will need one of the following types of photo ID:

•  UK photocard driving licence
• UK passport
• non-UK passport with a biometric chip
• UK biometric residence permit (BRP)
•  UK biometric residence card (BRC)
• UK Frontier Worker permit

Requirements for your phone

You will need access to a phone with a working camera.

If you’re using an iPhone, it must be running iOS 14 or higher and be either:

•  an iPhone 6s or newer if your photo ID is a UK driving licence
• an iPhone 7 or newer if you’re using any other type of photo ID

For an Android phone (for example, Samsung or Google Pixel), it must be running Android 10 or higher.

2. Answering security questions online

If you are unable to use the GOV.UK ID Check app on your phone, you can answer some security questions on the website. You may be asked to answer questions in relation to your mobile phone contract, and/or any bank accounts, credit cards, loans or mortgages you may have. You also need photo ID in form of UK passport or UK photocard driving licence.

3. Face to face at a Post Office

If neither of the above methods are suitable for you, you can verify your identity in person at a Post Office. To do so you will need to:

• Visit the GOV.UK One Login website where you will be asked to enter details from your photo ID,
• Visit a Post Office that offers ‘in branch verification’,

The Post Office will then scan your photo ID and take a picture of you for the verification process.

You will receive an email about the result of your identity check – according to the government, this should usually be within a day of going to the Post Office.

You will need one of the following types of photo ID: UK passport or non-UK passport, UK photocard driving licence, European Union (EU) photocard driving licence, UK biometric residence permit (BRP) or national identity photocard from an EU country, Norway, Iceland or Liechtenstein.

Using an Authorised Corporate Service Provider (ACSP)

If none of the 3 options above are available to or convenient for you, you may engage an ACSP to verify your identify, but it is likely that they will charge for this service.  They will still require at least one form of photographic ID.

Why choose to verify your identity now?

Although verification isn’t required yet, it will soon be mandatory and getting ahead of this requirement will avoid any last-minute issues, for example ensuring you have the necessary ID.  Those who don’t verify by the required date will be committing a criminal offence liable to a fine. Any company with outstanding unverified directors/ PSCs  may find this affects its access to finance and ongoing operations too.

What happens once you have verified your identity?

Once you have verified your identity, you will be issued with a unique identifier number which will be linked to all directorships.

Verification will usually be a “once and for all” step, there should be no need to re-verify if you change any of the details you provided at the point of verification.  All your roles at Companies House will be linked together, so you only need to verify once, even if you have multiple directorships or PSC positions.

How we can help

Further details of the changes and what companies need to do and by when can be found here: Changes to UK company law website.  You can also receive updates by subscribing to the Companies House newsletter.

For expert advice on any issues relating to ID verification or any other area of corporate law or governance, please do not hesitate to get in touch.