Companies House ID Checks Need Role-Based Planning

Companies House ID Checks Need Role-Based Planning

A single reminder labelled “Companies House identity checks” is not a control. The company needs to know who must act, in which capacity, through which route and by what date.

Companies House guidance says mandatory identity verification began on 18 November 2025. The transition arrangements and the point at which an existing person must provide their personal code depend on the role and filing route. Do not treat 18 November 2026 as a universal deadline for every director and person with significant control. Check the individual’s current due date in the official guidance. GOV.UK, When you need to verify your identity for Companies House GOV.UK, Verifying your identity for Companies House

Build a person-by-person register

For each relevant individual, record their name, company, role or roles, verification status, Companies House personal code status, applicable filing route, due date, internal owner and evidence location. If a person is both a director and a PSC, track both obligations separately rather than assuming one step satisfies both.

Keep personal codes in an appropriately restricted process. Do not circulate them in broad email chains or place them in a general task list. Give the company secretary or authorised filing owner a secure method to collect and use the code when required.

Tie the action to the right event

For directors, the code is provided through the relevant company filing process. PSCs have a separate route and timing rules that vary by circumstance. Changes in roles or the company’s filing timetable can alter what action is needed.

Use the Companies House register and current GOV.UK guidance to confirm the actual requirement for each person. If the status or date is unclear, resolve it before the filing window approaches. Do not infer a deadline from another company or another person’s role.

Make the evidence easy to retrieve

Retain confirmation that verification was completed and record when the personal code was provided through the correct route. Keep the evidence linked to the relevant company and role, with access limited to those who need it. A spreadsheet marked “done” is not enough if nobody can show the completion record.

Set an exception path for people who have not completed verification, whose information does not match, or whose personal code is unavailable. Escalate early to the responsible director or PSC and record the action taken. Keep the register under review when appointments, resignations or PSC changes occur.

Run a short readiness check

Before each relevant filing, reconcile the people list against current appointments and PSC information. Confirm who needs a code, whether the code has been obtained securely, who will submit it and where acceptance evidence will be stored.

The point is not to create another tracker. It is to prevent role confusion from becoming a missed filing or a late scramble. Use current official guidance for the specific case, assign one owner, and keep a record that proves the step was completed.