A Personal Code Is Not a Company Secretarial Control

A Personal Code Is Not a Company Secretarial Control

Identity verification creates a practical governance task: identify who must act, what step applies to their role and how completion is evidenced. A personal code sitting in someone's inbox does not prove that the company secretary has reconciled the process to the right Companies House record.

Companies House guidance sets out identity verification requirements for directors and people with significant control, including role-specific steps and timing. New directors and existing directors do not follow one identical workflow, and PSCs have their own requirements. Use the official guidance as the control source, not an old checklist copied from another company. Companies House, when to verify your identity and verify your identity

Reconcile people to roles before chasing completion

Maintain a current register of directors and PSCs for each entity. Record the person's role, relevant date, verification status, required next step, Companies House personal code status where applicable, responsible internal owner and evidence location. Reconcile that register to the company record and the organisation's own appointment records.

One person may hold more than one role. Do not assume that completing a step for one role automatically closes every related requirement. Check the current Companies House guidance for the person's actual circumstances and record the conclusion.

Treat the personal code as controlled information

Set a secure method for collecting and storing personal codes. Limit access to people who need them for company administration. Record whether the code has been obtained and used for the relevant filing step, but avoid circulating it casually through email chains or broad spreadsheets.

The control should prove the process without unnecessarily spreading sensitive personal information. Define who can update the status, who can approve exceptions and how access is removed when a role changes.

Connect status to the filing calendar

Map each person's next required action to the relevant appointment or filing event. A single annual reminder is not enough when directors, PSCs and new appointments can have different steps. Use a forward-looking calendar with a named owner, a lead time and an escalation route for missing information.

At each confirmation statement cycle, reconcile the people register, verification evidence and filing data before submission. If records do not match, stop and resolve the discrepancy. Do not let a green tick conceal an unresolved identity or role question.

Make exceptions visible

Track the people who have not completed the required step, the reason, the next action and the decision-maker. Escalate overdue or uncertain cases to the company secretary or appropriate adviser. Keep evidence of completion and review the record when appointments, control status or filing responsibilities change.

A sound CoSec process is not built around one deadline. It is a repeatable control over people, roles, evidence and filings. Check the official guidance when the rules or a person's circumstances change. The aim is simple: accurate company records and a process that stands up to scrutiny.