To ID verify or not to ID verify?: The impact of Companies House ID checks on charitable companies and social enterprises

Author
Anne-Marie Marshall, Services Manager
Salford CVS

 

From 18th November 2025, identity verification became a legal requirement for company directors. This includes directors and trustees of charitable companies and social enterprises.

The change was introduced through the Economic Crime and Corporate Transparency Act 2023. Before this, companies could be created and run with very few checks on who was really in control. This made it easier for companies to be misused for fraud and other economic crimes.

Under the new rules, directors, trustees and people with significant control must now prove their identity. This improves the accuracy of the Companies House register and helps build trust in organisations that operate responsibly.

For charities and social enterprises, this strengthens transparency, protects their reputations, and reassures funders, partners, and the public.

Which charities are affected?

Only charities that are:

  • Registered with Companies House as a company limited by guarantee, and
  • Also registered with the Charity Commission

These organisations are often called charitable companies, and their directors are usually referred to as charity trustees.

Other types of charities, including Charitable Incorporated Organisations (CIOs), are not registered with Companies House. They are regulated solely by the Charity Commission and, at present, do not need to complete Companies House ID verification.

What does this mean in practice?

  • All directors and trustees of charitable companies must verify their identity.
  • Acting as a director or trustee without verification is illegal and can lead to fines.
  • Companies House can block filings, including the confirmation statement, or take enforcement action if directors are not verified.
  • The organisation can face penalties even if most directors have already completed verification.
  • Being a charity does not exempt directors or trustees from these requirements.

In addition, some people who file documents with Companies House, such as company secretaries, will also need to verify their identity as the new rules are phased in.

Who needs to verify their identity?
  • Company directors, including trustees of charitable companies
  • People with significant control (PSCs)
  • Certain people who file documents at Companies House, such as company secretaries
  • Authorised agents, known as Authorised Corporate Service Providers (ACSPs)
What should organisations do now?
  • Check when your directors or trustees need to verify their identity. This information is shown on the “People” tab of your Companies House record.
  • Tell directors and trustees about the new legal requirement, both in writing and at a board meeting.
  • Give as much notice as possible before deadlines. Some people find the process technical and may need extra time or support.
How can directors or trustees verify their ID?

There are three main options:

  1. Online verification
    Directors and trustees can verify their identity themselves using the GOV.UK One Login service, usually with a passport or driving licence.
  2. Post Office verification
    Directors and trustees can verify their identity in person at a participating Post Office. This option is free when arranged through GOV.UK.
  3. Using an Authorised Corporate Service Provider (ACSP)
    Some professional advisers, such as accountants, solicitors and governance professionals, can complete verification on behalf of directors. These services usually charge a fee.

Any third party carrying out ID checks for Companies House must be registered as an ACSP and meet the same standards as Companies House itself.

What if a director or trustee refuses to verify their ID?

You have limited options:

  • Explain that verification is a legal requirement, and they cannot continue in the role without it.
  • Ask them to resign if they refuse to comply.
  • If they do not resign, follow the formal process to remove them.

Under section 168 of the Companies Act 2006, a director can be removed by an ordinary resolution, following the required special notice procedure.

For charitable companies, your constitution may include provisions for removal. However, director removal is governed by the Companies Act 2006, even though the organisation is also regulated by the Charity Commission.

You should also review your constitution carefully, as the loss of a director may affect the organisation's ability to continue operating. Many funders, particularly for social enterprises, expect boards to have at least three directors.

Bottom line

Identity verification is now a legal requirement for UK company directors. A director or trustee who refuses to complete it cannot lawfully continue in their role. The organisation may be unable to file its confirmation statement, putting it in breach of the law. Ongoing non‑compliance can lead to fines, director disqualification and the risk of the company being struck off. In practice, refusal to verify leaves organisations with little choice but to take compliance action.

Support available

The Charity Commission is operating a transition period until November 2026 to allow organisations time to adjust. Deadlines for ID verification vary and are often linked to the next confirmation statement.

Support includes:

  • A free online GOV.UK verification service
  • Clear guidance on what is required and when
  • Help with personal verification codes
  • Additional support for people who need accessibility adjustments or struggle with digital processes

At Salford CVS, you can speak to us about these issues and explore options to address them.
Email: Office@salfordcvs.co.uk

And finally…

This does add another administrative step, but it is now part of the legal framework and good governance. The process may take some time, but in most cases it only needs to be done once. For boards of directors and trustees, it can also be a useful opportunity to review roles, responsibilities and collective accountability.

Guidance links:

 

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