Companies House Identity Checks Need an Operating Owner

Companies House Identity Checks Need an Operating Owner

Identity verification becomes a failure point when responsibility is split between directors, HR, legal and the company secretarial team, with nobody accountable for the complete filing journey.

Companies House guidance explains when directors and people with significant control need to verify their identity and when a personal code is required. Triggers differ by role and circumstance. Do not apply one copied deadline to everyone. Check the current official guidance for each person and filing. Companies House, When you need to verify your identity

Build a controlled register

Maintain a restricted-access record for each relevant individual: role, verification status, applicable filing trigger, accountable owner, personal-code handling status and evidence that the filing was accepted. Keep the code itself in an appropriately controlled channel. It is personal information, not a general-purpose company reference.

Separate the process into two controls: the individual completes verification and the company completes the correct filing step. One does not prove the other. Record who checks each stage and what evidence closes it.

Connect the register to real events

Tie the workflow to director appointments, changes in control, confirmation-statement preparation and other relevant filing events. Add an early check to the board and governance calendar, then assign a named person to resolve missing information before the filing is submitted.

For new appointments, include identity-verification readiness in the appointment checklist. For existing directors and PSCs, confirm the relevant transition and filing trigger against current Companies House guidance. If the position is unclear, obtain advice before treating the item as complete.

Make exceptions visible

Use clear statuses: verified and ready, action required, trigger not yet reached, or evidence incomplete. Give exceptions an owner and review date. Do not mark a person green because an email was sent or a code was requested.

Before a filing, reconcile the people in scope against the company record. After submission, retain confirmation and update the register. That simple loop prevents the same gap being rediscovered under deadline pressure.

Protect accuracy and access

Limit access to personal codes, keep an audit trail of who handled them, and use the official filing route. Avoid copying sensitive data into broad trackers or board papers. The company secretary should own the workflow and escalation, while each individual remains responsible for completing their own verification steps.

This is not clerical tidying. It is a repeatable governance control. Put an owner on it, connect it to filing events and require evidence before declaring the process complete.