Written by Charlie Daw
New Companies House identity verification requirements are raising questions for some directors and trustees – particularly older people who may not have a passport or driving licence. As part of changes introduced through the Economic Crime and Corporate Transparency Act, Companies House is introducing mandatory identity verification for company directors and people with significant control (PSCs).
Identity verification became a legal requirement in November 2025, with a 12-month transition period giving existing companies time to make sure their directors and PSCs complete the process. For charities and community organisations, this is particularly relevant where trustees are also directors of an incorporated charity or company limited by guarantee.
What is identity verification?
The new requirement is intended to help Companies House establish that people appearing on the register are who they claim to be, reducing the risk of fraud and improving the accuracy and reliability of the register.
People can verify their identity directly through Companies House using GOV.UK One Login, or they can use an Authorised Corporate Service Provider (ACSP), such as an accountant or solicitor, to complete the verification on their behalf.
But what if someone doesn’t have a passport or driving licence?
This is where some organisations are finding themselves facing practical difficulties.
The standard online route is designed around photographic identity documents. GOV.UK lists documents including a biometric passport, UK photo driving licence and certain biometric immigration documents for the One Login process. That can create a particular barrier for some who have never driven, no longer drive, or do not have a passport.
An ACSP could provide another route
An Authorised Corporate Service Provider (ACSP) is an agent authorised by Companies House to carry out certain services, including identity verification. They can include accountants, solicitors and other AML-supervised professionals. If someone is struggling with the standard online process, they can ask an existing accountant, solicitor or other appropriate professional whether they are registered as an ACSP.
Companies House also publishes a list of ACSPs that have chosen to make their details public. However, Companies House stresses that it does not endorse or recommend individual providers, and the list may not contain every registered ACSP. Organisations should check what services an agent offers, what they charge and whether they can provide verification remotely or in person.
When an ACSP carries out the verification, the individual will need to provide their name, home address, email address and suitable evidence of identity. The ACSP is responsible for carrying out the checks to the standard set by Companies House.
What happens after verification?
Once verification has been completed, Companies House sends the individual a personal code to the email address provided during the process.
The code is then used to connect the person’s verified identity with their Companies House record.
A verification statement will appear on the public register showing the person’s name, the date their identity was verified, the ACSP that carried out the verification and the AML supervisory bodies with which that ACSP is registered.
It is therefore important that anyone going through the process keeps access to the email address they provide.
What should charities and community organisations do?
For organisations with trustees who are also company directors, it is worth checking now who needs to complete identity verification and whether everyone can access one of the available routes.
In particular, organisations may want to identify trustees who:
- do not have a passport or driving licence;
- are not confident using digital services;
- do not have access to a suitable smartphone or device;
- may require reasonable adjustments;
- or may need support from an ACSP to complete the process.
The important point is that not having a passport or driving licence does not necessarily mean someone cannot complete identity verification. There are alternative routes, including the Post Office route within GOV.UK One Login, ACSP verification and support or reasonable adjustments from Companies House where appropriate.
However, you should not leave it until the last minute. Companies House has warned that directors who fail to meet the verification requirements by their deadline may be committing an offence, and companies may ultimately be unable to file their confirmation statement if their directors have not completed verification.