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CIC Directors Must Verify Their ID: The New Companies House Rules (What, When, How)

Applies from 18 November 2025 (12-month transition period)

The UK is entering a new era of corporate transparency. From 18 November 2025, identity verification becomes a legal requirement for company officers, including Community Interest Companies (CICs). The change sits within the Economic Crime and Corporate Transparency reforms and will be enforced by Companies House with new digital systems and stricter filing controls.

At Third Sector Experts International, we help CICs and charity-style social enterprises stay compliant without losing momentum on mission. Here’s what your board needs to know and do now.

 

Blue and black abstract logo on the left with text "COMMUNITY INTEREST COMPANIES" on the right. Bold font, professional design.

1) Who must verify (and who later)

From 18 November 2025, identity verification applies to:

  • All company directors (including CIC directors)

  • People with Significant Control (PSCs)

  • Anyone who files on behalf of the company (presenters/agents), either verify themselves or operate via an Authorised Corporate Service Provider (ACSP)

Companies House confirms that identity verification for limited partnerships, corporate directors, corporate members of LLPs, and officers of corporate PSCs will be introduced later (date TBC).

 

2) Timeline and due dates

  • 18 November 2025: legal requirement begins.

  • This date marks the start of a 12-month transition period; it is not a deadline.

  • After 18 November, each person will see a verification due date per role on the Companies House register.

  • New appointees (e.g., a new CIC director) will typically need to verify before or at appointment; existing officers must verify by the due date shown for each role.

If you’ve already verified, you don’t verify again, but you must provide your personal code for each role you hold.

 

3) What happens if you don’t verify

The first immediate lever is your confirmation statement:

  • From 18 November 2025, you will not be able to file your next confirmation statement unless all company directors have verified and their personal codes are included.

  • If someone files on your behalf, each director must share their personal code with the filer.

Failure to verify and/or file on time can escalate to late-filing penalties, compliance flags, and ultimately compulsory strike-off. Practically: no verification = no valid filing, which is a serious operational risk for any CIC.

 

4) How to verify: two routes

A) Direct via Companies House Use the Verify your identity for Companies House service (via GOV.UK One Login). The system will guide you through the quickest path based on your device and ID:

  • UK photocard driving licence, UK passport, or non-UK biometric passport with a smartphone is the fastest route (ID app + live photo).

B) Via an ACSP (Authorised Corporate Service Provider) An accountant, solicitor, or supervised agent can complete verification on your behalf and confirm it to Companies House. (Third Sector Experts International can coordinate this via supervised partners.)

Once verified, you receive a Companies House personal code. You must supply that code for each role you hold (e.g., director of CIC A, PSC of CIC B).

 

5) What CICs need to do now (board-level actions)

  1. Map the roles


    List every director, PSC, and filer/agent attached to the CIC. Include founders who remain on the register but aren’t active day-to-day.

  2. Clean the register


    Check and correct: registered email address, service addresses, officer names, PSC records. Inaccuracies can delay verification and filing.

  3. Choose the route


    Decide whether directors/PSCs will verify directly or through an ACSP. Agree who will collect and submit personal codes with filings.

  4. Sequence the work


    Prioritise anyone with imminent confirmation statement dates and new appointments planned after 18 November 2025.

  5. Brief the board


    Make verification a standing agenda item until all roles show verified with codes recorded in your internal compliance register.

  6. Update your controls

  7. Add ID verification steps to board onboarding/offboarding checklists.

  8. Incorporate personal code capture into your internal company secretarial process.

  9. Set reminders for role-specific due dates (they can differ per role/person).

 

6) Practicalities and good practice

  • Central log: Maintain a secure register of who has verified, their personal code, and any role-specific due dates.

  • Delegation: If using an ACSP or internal company secretary, ensure you have written authority to process and store personal codes securely.

  • Data protection: Treat personal codes and ID data as confidential; restrict access and document your lawful basis (legitimate interests/legal obligation).

  • Onboarding: For any new director/PSC after 18 November 2025, build “verify + provide code” into the appointment checklist; no verification, no appointment.

  • Offboarding: When directors step down, ensure filings reflect the change and your internal register is updated.

 

7) Communications: what to tell stakeholders

  • To directors/PSCs: Verification is mandatory and time-bound; share the Companies House video/guidance and set an internal deadline ahead of the official due date.

  • To your filer/agent: Confirm who will collect and input personal codes; test your process on a dummy run ahead of your next confirmation statement.

  • To the board: Provide monthly status until 100% of required roles are verified and codes recorded.

 

8) Common pitfalls to avoid

  • Assuming one code covers everything: you must provide your personal code for each role you hold.

  • Leaving it to filing day: the portal or ID app may need extra checks—start early.

  • Out-of-date officer records: unremoved leavers or old addresses complicate verification and filings.

  • Unclear internal ownership: nominate a single compliance lead to chase statuses and maintain the log.

 

9) How Third Sector Experts International can help

We support CICs to get “verification-ready” with:

  • CIC Compliance Audit: clean your officer/PSC records, map roles, confirm due dates.

  • Verification Route Plan: choose direct vs ACSP, coordinate sessions, and create scripts/instructions for your board.

  • Company Secretarial Pack: updated onboarding/offboarding checklists, data handling notes, and a personal-code register template.

  • Filing Readiness: rehearsal of your confirmation statement process with codes included.

Verification is quick for most people, but designing a reliable process is what keeps you compliant.

 

Final thoughts

These reforms are about credibility. For CICs, organisations trading for community benefit, transparent leadership identities will strengthen trust with funders, partners, and the public.

Start now: verify early, capture personal codes, test your filing flow, and keep your board informed. With a clear plan, the November 2025 start line becomes a non-event.

 

Download our CIC Identity Verification Checklist (Directors & PSCs)

 

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