Calling all Community Interest Companies (CIC’s) and Charitable Companies, there has been a change in the law that you need to know about.
From 18th November 2025, identity verification will be required for all newly registering directors and all people with significant control (PSCs), whether they are new or not.
The background
Since April 2025, under the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023), people have been able to voluntarily verify their identity with Companies House.
When I say people, I mean directors, anyone equivalent to a director, any person who is not a director but files on behalf of the company, and any other person who has significant control. A person with significant control (PSC) is someone who controls more than 25% of the board votes and/or has he ability to remove or replace directors.
This can also include someone who in some other way holds significant control over the organisation- perhaps by having a veto. This change also affects CIC’s governed by shares, although they cannot be members of Salford CVS.
It’s worth bearing in mind if you are involved with any other type of company. In organisations with shares including some models of CIC, control of more than 25% of the shares makes you a person with significant control. Sometimes people with significant control are also known as Beneficial Owners.
Why is this important?
This is important because, from 18th November this year, it will be mandatory to provide a code linked to your virtual ID for new registrations and all PSC’s and it will be a criminal offence if you do not. Additionally, you will not be able to perform certain actions without first verifying, including incorporating a new organisation and filing returns.
What do you mean by verify?
Identification through the government is usually linked to biometric data, which, for example, is on your passport. There are several different methods of verification, but there is a free government option.
When you verify, you will be given a code. It is important to note that if you have two roles within an organisation, different procedures may apply and you may need more than one code. Links below explain the various ways to verify.
What is it important for?
This code is personal and unique to you, not your company. You'll be required to provide it when you're appointed to a new role, or for existing directors and PSCs, as part of the confirmation statement or other filings starting from autumn 2025.
When do I have to do this?
- 18th November 2025: Identity verification becomes mandatory for anyone establishing a new company. It will also be a requirement for all newly appointed directors and all Persons with Significant Control (PSCs) already in existing companies.
- 18th November 2025 (and for 12 months after): Existing directors will have a 12-month grace period to verify their identities. Companies House will seamlessly integrate this process into the company's annual confirmation statement, so existing directors will need to confirm they have verified their identity when submitting their next confirmation statement.
- 18th November 2026: Looking ahead, it will be a legal requirement for anyone submitting documents at Companies House on behalf of a company to have their identity verified, and there is some indication that all directors whether they are PSCs or not will eventually have to have VID.
Don’t forget that this is mandatory for persons with significant control in new and existing companies from 18th November. There doesn’t appear to be any additional time allowance for PSCs in existing companies. So from the 18th of November existing PSC’s will have a 14-day period to comply with identity verification requirements.
Although it is not mandatory now, you may wish to do it in advance so that you are compliant before 18th November and any issues are dealt with early.
Going forward, you will need to add directors and persons with significant control at the same time as they are ready to be put on the register at Companies House. In terms of charitable companies, the IDV is probably best done at the same time as you carry out your checks on new trustees/directors for the Charity Commission.
It is also worth noting that this will significantly change the persons with significant control register; it will eliminate separate PSC registers and instead require companies to upload their PSC details directly to Companies House, which will become the central public register. This may, in turn, make checks on trustees and directors easier and serve as another good tool to establish conflicts of interest.
More info:
www.gov.uk/using-your-gov-uk-one-login/proving-your-identity
www.gov.uk/guidance/verify-your-identity-for-companies-house
www.gov.uk/guidance/when-you-need-to-verify-your-identity-for-companies-house