PSC and director identity verification UK: the 2026 Companies House compliance guide

On 18 November 2025, Companies House identity verification requirements came into force for UK company directors and People with Significant Control (PSCs). Under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), directors and PSCs must now verify their identity with Companies House — and there are, in fact, two separate verification requirements running in parallel.

ECCTA represents the most significant reform of Companies House rules in a generation. The identity verification requirements are being phased in alongside broader changes to how Companies House operates, with new obligations applying to new appointments immediately and existing officeholders given a transition period.

This guide explains, in plain English, the two separate identity checks that UK directors and PSCs need to navigate: who has to verify, when, how, what a "Companies House personal code" (also known as a Unique Personal Code or UPC) is, and what may happen if you don't comply.

Director identity verification vs PSC identity verification: what's the difference?

The first and most common confusion: these are two separate legal requirements, both introduced by ECCTA. Although both came into force on 18 November 2025, they apply to different roles and are triggered by different filings.

• Director identity verification applies to every individual appointed as a director of a UK company — regardless of whether they own shares. The director's personal code is required on director-specific filings such as the AP01 (appointment) and confirmation statement.
• PSC identity verification applies to every individual who qualifies as a Person with Significant Control — regardless of whether they sit on the board. The PSC's personal code is required on PSC notifications (e.g. PSC01) and the confirmation statement.

Plenty of people are both: the classic sole founder who owns 100% of the shares and is the only director is simultaneously a director and a PSC. In that case, one identity verification covers both roles — verification attaches to the person, not to a specific role — and Companies House issues a single personal code (also called a Unique Personal Code or UPC) that the company uses in both director filings and PSC filings.

Where the two requirements diverge is when someone is only a director (e.g. a non-executive with no shares) or only a PSC (e.g. an investor holding 40% with no board seat). Each person still needs to verify under the requirement that applies to their role, and their personal code must appear on the relevant filings.

What is a Person with Significant Control (PSC)?

A PSC is anyone who ultimately owns or controls a UK company. Companies House maintains a public PSC register for every company precisely so the public can see who is really behind a business — not just the nominee directors or shell entities on the surface.

The five ways someone becomes a PSC

You are a PSC if you meet any one of these conditions:

• You hold, directly or indirectly, more than 25% of the company's shares.
• You hold, directly or indirectly, more than 25% of the voting rights.
• You have the right to appoint or remove a majority of the board of directors.
• You have the right to exercise, or actually exercise, significant influence or control over the company.
• You have the right to exercise, or actually exercise, significant influence or control over a trust or firm that itself meets one of the above conditions.

Note the threshold: more than 25%, not 25% or more. Holding exactly a quarter does not make you a PSC on the ownership condition — but you might still qualify via one of the other four routes.

Relevant Legal Entities (RLEs): corporate PSCs

If a company (rather than an individual) sits at the top of the ownership chain, the rules are different. The corporate entity is recorded on the register as a Relevant Legal Entity (RLE), and the verification obligation shifts to the individuals who ultimately control that entity — the humans behind the corporate veil. Group structures, family investment companies, and nominee arrangements all need to be unwrapped to find the natural persons who must verify.

Who needs to verify their identity?

Every natural person who sits in one of these roles must complete identity verification:

• All directors of UK limited companies (including LLP members in designated roles).
• All individual PSCs, including PSCs of companies where an RLE sits between them and the company.

Note that professionals who file on behalf of a company — such as accountants, solicitors, formation agents, and company secretaries — do not need their own personal code for this purpose. However, from April 2026, third-party filings must be submitted through a registered Authorised Corporate Service Provider (ACSP). ACSPs can include accountancy firms, law firms, company formation agents, and other regulated service providers — the ecosystem of registered ACSPs is still growing. ACSP registration is a separate regime from the director and PSC identity verification described here.

Verification is intended to be a one-off process. Under the current rules, once a person is verified, they do not need to repeat the check for each new directorship, PSC role, or company they are involved in. The single personal code they receive is reused across every filing that relates to them. However, Companies House retains the power to require re-verification in certain circumstances, so it is worth keeping your identity documents accessible.

When do you need to verify?

Deadlines depend on whether you are a new appointment or an existing director/PSC, and whether you are an individual or a company. Here is the plain-English version.

New directors — verify before the AP01 is filed

Where ECCTA identity verification is in force, a new director's personal code (UPC) is required for Companies House to accept the AP01 appointment form. In practice, this means the director must complete verification and obtain their personal code before the AP01 is submitted — typically within the 14-day filing window from the date of appointment. If the personal code is not available, the AP01 may be rejected, while the statutory 14-day deadline continues to run. (We cover the full sequence in our director-appointment playbook.)

New PSCs — typically within 14 days of becoming a PSC

Where an individual newly qualifies as a PSC — after a share issue, transfer, or shareholders' agreement change — the company must notify Companies House within 14 days (via form PSC01). The new PSC's personal code is needed for the notification to be accepted. If a new PSC has not yet completed verification, the filing may be rejected and the company risks falling out of compliance with its notification obligations.

Existing directors — by the next confirmation statement

Directors already on the register at 18 November 2025 have a transition window to verify. In practice, verification is expected to be complete by the time the company files its next confirmation statement after the ECCTA commencement date — giving up to twelve months plus the 14-day filing window. Leave it to the last minute and you risk the confirmation statement itself being rejected.

Existing PSCs — same transition window

Individuals who were already PSCs on 18 November 2025 are handled on the same transition timetable as existing directors: verify by the next confirmation statement after commencement. Companies House treats PSC verification as part of the confirmation-statement checks from that point on.

How to verify: the two-step process

Identity verification, in Companies House's new regime, is a two-step process:

1. Complete identity verification — either directly via GOV.UK One Login or through an Authorised Corporate Service Provider (ACSP).
2. Receive your Companies House personal code — an 11-character code issued once verification is approved. This code is what links your verified identity to every Companies House filing that refers to you.

Step 1, Option A: Direct verification via GOV.UK One Login

The free, self-service route. You create (or log into) a GOV.UK One Login account, upload a government-issued photo ID — typically a UK or international passport, or a UK photocard driving licence — and complete a facial-recognition "liveness" check using your phone or webcam. The system cross-references your document against government records.

It works well when it works, but has known failure modes with older document types, certain non-UK passports, and poor lighting during the biometric check. If a first attempt fails, there is sometimes a cooling-off period before you can retry.

Step 1, Option B: Verification through an Authorised Corporate Service Provider (ACSP)

An ACSP is a firm — such as an accountancy practice, law firm, or company formation agent — that is authorised by Companies House to carry out identity checks to the same standard as the direct route. The ACSP reviews your identity documents, confirms your identity, and submits the verification to Companies House on your behalf. Filing HQ is a registered Companies House ACSP — so we can verify your identity directly, without requiring you to use GOV.UK One Login or go through the biometric app.

The ACSP route tends to be faster and more forgiving for overseas directors, holders of non-standard ID documents, or anyone who just wants a person rather than an app on the other end of the process.

Step 2: Receive and use your personal code

Once verification is approved, Companies House issues the individual a personal code (UPC). This code is required whenever a company files something about you — a new director appointment (AP01), a PSC notification (PSC01), or the annual confirmation statement (CS01). The person preparing the filing enters your personal code, Companies House checks it against your verified record, and — if it matches — the filing is accepted.

The personal code is yours, not the company's. Keep it somewhere secure and share it with the person doing the filing — never post it publicly or send it by unsecured channels.

What is a Companies House personal code (UPC)?

The Companies House personal code — sometimes referred to as a Unique Personal Code (UPC) — is an 11-character identifier issued to an individual after they successfully complete identity verification. It links your verified identity to Companies House filings: whoever submits a filing that refers to you must include your personal code, and Companies House checks that the code matches a verified individual on their records before accepting the filing.

A few things worth knowing:

• The code is per person, not per company. You have one code that follows you across every company you direct or control.
• Under the current rules, the code remains valid without a set expiry date. However, Companies House retains the ability to require re-verification in certain circumstances, so treat it as long-lived rather than permanent.
• Sharing the code with whoever prepares your filings — whether that is an accountant, solicitor, formation agent, ACSP, or company secretary — is expected. Sharing it publicly is not.
• If you lose the code, Companies House can reissue it — but the process takes time, which is why most founders keep it stored with their other company documents.

What happens if you don't verify

ECCTA gives Companies House broader enforcement powers than it had previously. Non-compliance with identity verification requirements can have practical and legal consequences, including:

• Rejected filings. Companies House may refuse to accept filings — such as AP01 appointments, PSC01 notifications, or confirmation statements — where the required personal code is missing or does not match a verified individual. This can prevent a company from completing routine compliance activities.
• Potential enforcement action. Under ECCTA, failing to comply with identity verification obligations may constitute an offence. This could result in fines or, in serious cases, further enforcement action against the individual or the company's officers. The exact approach Companies House takes to enforcement is still developing as the regime beds in.
• Register annotations. Companies House has the power to annotate the public register to flag non-compliance. These annotations are visible to anyone searching the company record — including banks, investors, clients, and landlords carrying out due diligence.
• Commercial consequences. Procurement teams, lenders, and payment processors increasingly check Companies House records before doing business. Incomplete or non-compliant filings can raise concerns during due diligence and may affect commercial relationships.

Common mistakes to avoid

1. Assuming "director verification" covers PSC verification, or vice versa. If you are both a director and a PSC, the same personal code covers both — but if you only verified as a director and you are not a PSC, that doesn't automatically resolve a PSC requirement for someone else on your register.
2. Leaving existing directors/PSCs to the last minute. The transition window runs to your next confirmation statement. Leave the verification until the day you file and you risk the confirmation statement being rejected, which could lead to further compliance issues.
3. Treating "my company is dormant" as an exemption. It isn't. A dormant company is still on the register, still has directors, and still has at least one PSC. All of them must verify.
4. Forgetting overseas PSCs. Being based outside the UK does not exempt anyone from verification. GOV.UK One Login may struggle with non-UK IDs, which is exactly where the ACSP route is designed to step in.
5. Misunderstanding the 25% threshold. The threshold is more than 25%, not 25% or more. But significant influence or control, or board appointment rights, can make someone a PSC even below 25% — don't rely on the share number alone.
6. Letting the personal code sit in an inbox. Store it with your other company documents. Losing it means waiting for a reissue, which is exactly when you'll need to file something urgent.

Frequently asked questions

I already verified my identity as a director. Do I need to do it again for PSC?

No — if the same person is both a director and a PSC, one identity verification covers both roles. You have one personal code as an individual, and it is used on both director filings and PSC filings about you. Check your Companies House record to confirm both flags show as verified.

My company is dormant. Do I still need to verify?

Yes. A dormant company is still a live UK company on the register, with directors and PSCs. Identity verification applies regardless of whether the company is trading. See our dormant company compliance checklist for the full picture.

I hold exactly 25% of the shares. Am I a PSC?

Not on the ownership condition. The threshold is more than 25%. However, you could still qualify as a PSC under one of the other four conditions — for example, if your shareholders' agreement gives you the right to appoint a majority of directors or exercise significant influence or control.

My PSC lives abroad and can't use GOV.UK One Login. What now?

This is precisely what ACSPs are for. An overseas PSC can be verified by an Authorised Corporate Service Provider without needing GOV.UK One Login. Filing HQ regularly verifies overseas PSCs as part of our PSC verification service.

What is a Companies House personal code, in one sentence?

It is an 11-character Unique Personal Code (UPC) issued to an individual after they complete identity verification. Any Companies House filing that involves that person — such as a director appointment, PSC notification, or confirmation statement — must include the code so Companies House can confirm the person is verified.

How long does verification take?

Through GOV.UK One Login, verification can be instant if everything works first time — or several attempts over days if the biometric check struggles. Through an ACSP like Filing HQ, verification is typically completed within 1–3 working days from receiving your ID documents.

How Filing HQ makes verification painless

We built our PSC verification service and director identity verification service because the legislation is clear in principle but tangled in practice — especially for companies with multiple shareholders, overseas PSCs, corporate shareholders sitting in the chain, or transition-period deadlines creeping up next to a confirmation statement.

As a registered Companies House Authorised Corporate Service Provider (ACSP), Filing HQ can verify your identity directly and deliver your personal code (UPC) without any GOV.UK One Login wrangling. If your company has multiple directors and PSCs, we handle each individually, make sure the register is accurate first, and file the right statements. Our packages bundle verification with your confirmation statement, registered office, and compliance filings, so verification fits into a clean annual rhythm rather than becoming a separate task.