By Edward Young, Notary Public London
A Law That Changes Everything
For more than 150 years, Companies House has been the custodian of the UK’s
corporate register. Its traditional model was simple: companies submitted
information, and Companies House recorded it.
That approach is now widely seen as outdated. The register has long contained fake
names, dummy directors, and companies created to launder money or evade
sanctions. Investigations even uncovered firms with “Donald Duck” listed as a
director.
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) is the
government’s response. At its core is a significant shift: anyone who is a company
director, a person with significant control (PSC), or filing on behalf of a company
must now verify their identity.
Why Identity Verification Matters
The government’s goals are clear:
- Prevent economic crime by reducing fraud and money laundering.
- Improve register accuracy so businesses and regulators can rely on data.
- Increase transparency of ownership structures.
- Rebuild trust in the UK as a place to do business.
It is a major policy shift designed to make the UK corporate environment safer and
more credible. In practice, millions of individuals must take action over the next year.
Who Needs to Verify
The rules are broad in scope:
- New directors must verify before appointment.
- Existing directors must verify within 12 months of November 2025.
- PSCs must also verify, aligned with confirmation statements.
- LLP and LP members
- Company secretaries
- Individuals filing on behalf of companies
Put simply: if you are connected to a UK company or LLP, verification will become unavoidable.
Two Routes to Verification
1. GOV.UK One Login
Individuals can verify through the government’s One Login platform by:
- Uploading a passport, driving licence, or biometric residence permit.
- Taking a live selfie with the ID Check app.
- Answering security questions.
If successful, Companies House issues a unique personal code to be used for
company filings. Verification is free and relatively quick but can suffer from technical
glitches and lacks human support.
2. Through an Authorised Corporate Service Provider (ACSP)
Alternatively, directors can verify via regulated professionals such as solicitors,
accountants, or notaries registered as ACSPs. They check ID documents, confirm
identity, and notify Companies House.
This option is often chosen by non-resident directors, high-net-worth individuals, or
those wary of uploading biometric data to government systems. The drawback is that
very few firms are currently offering the service, leaving a gap in provision.
Problems Already Emerging
Although mandatory verification begins in late 2025, the voluntary phase has
highlighted several issues:
1. Technical failures – App rejections due to lighting, camera quality, or minor discrepancies.
2. Delays – Some applicants wait weeks for approvals.
3. Privacy concerns – Unease about centralised storage of sensitive data.
4. Few professional providers – Many accountants and law firms have not set up ACSP services.
5. Risk of penalties – Failure to verify can block company filings and trigger fines or criminal liability.
Practical Advice for Directors
- Know your role: deadlines differ for directors, PSCs, and agents.
- Start early: don’t wait until the transition window closes.
- Choose your method: decide between GOV.UK or an ACSP.
- Keep records: store your Companies House personal code securely.
- Coordinate internally: larger firms should ensure all relevant officers comply.
Why This Will Be Painful
The scale is immense: the UK has around 4.6 million active companies. Once
directors, PSCs, and LLP members are factored in, some 8–9 million individuals will
need verification. Expect backlogs and technical bottlenecks.
GOV.UK systems alone cannot carry the load. ACSPs will be essential to bridge the
gap.
Where ACSPs Fit In
As a notary public, I verify identities daily for international transactions. I already
have systems to check passports, certify true copies, and store compliant records.
Notary Public London – Edward Young now applies those processes to ECCTA,
offering:
- Expedited verification for existing clients.
- Online checks using secure technology.
- In-person verification at our London office.
- Premium support for high-net-worth clients.
Few firms have embraced this responsibility. We have chosen to do so.
Broader Impact on UK Business
- Cleaner register: expect thousands of dormant or fraudulent companies to be struck off.
- Higher compliance costs: directors will pay in time (DIY) or money (ACSP fees).
- More pressure on small firms: sole directors may find the process daunting.
- Expanded Companies House powers: shifting from passive recorder to active regulator.
For decades, company formation in the UK has been effortless. With ECCTA, the
balance shifts toward scrutiny and accountability.
Final Thoughts
The ECCTA identity verification regime is the most significant change to UK
company law in decades. It is not optional, not trivial, and not something to ignore.
The message is simple: act early, choose wisely, and don’t underestimate the
consequences of delay.
The UK must show the world that its corporate register can be trusted. That will only
happen if individuals and companies take their responsibilities seriously.
Edward Young
Notary Public London
EY@notarypubliclondon.co.uk
