Charitable Companies: Changes to Companies House identity verification regime
Trustees of charitable companies need to be aware of the new identity verification regime being introduced by Companies House, as part of the mandatory requirements set out in the Economic Crime and Corporate Transparency Act 2023.
From the 18 November 2025, identity verification will be imposed on trustees and people with significant control (PSC) with an intention to boost business and support growth by making it harder to register false trustees and beneficial owners, and gives greater assurance about those setting up and controlling companies, including charitable companies.
Who is subject to identity verification?
The new regime will require trustees who are setting up, running, owning or controlling a charitable company in the United Kingdom to verify their identity, as a means of proving who they claim to be.
Identity verification will be required for new and existing trustees and PSCs of charitable companies. At a later date, Companies House intends to broaden this list extensively to those who file at Companies House, limited partnerships, corporate directors of companies, corporate members of limited liability partnerships and officers of corporate PSCs.
Implementation of regime
The proposed timeline for the implementation of the identity verification regime is set out below.
- 8 April 2025 – voluntary identity verification introduced.
- 18 November 2025 – identity verification will be compulsory for trustees and PSCs in connection with incorporation and new appointments. Existing trustees and PSCs will have a 12-month transition period from this date.
- Spring 2026 – identity verification will become compulsory for anyone filing documents at Companies House.
- End of 2026 – Transition period will end, and all new and existing trustees and PSCs will be subject to compliance checks by Companies House.
How can you verify identity?
Verification can be undertaken in various ways, including directly with Companies House or through an authorised corporate service provider (ACSPs). Which verification route an individual chooses will determine which identity documents will need to be provided.
If verification is being undertaken directly with Companies House, this can be done through the UK One Login Check App, UK One Login Web service, or face to face at selected post offices.
Alternatively, ACSPs, who are professional intermediaries that have the necessary anti-money laundering training, and are therefore equipped to verify ID documents, can assist with verification.
Completion of verification
Following successful completion of verification, Companies House will issue a unique identifier known as a Companies House personal code. This personal code should be kept safe and secure, and will be used to connect an individual’s verified identity with Companies House records for all company roles they hold.
Non-compliance with identity verification regime
Once identity verification becomes mandatory, failure to comply may result in the commission of an offence, which may attract a financial penalty. This includes acting as a trustee or PSC without undertaking identity verification as set out above. Individuals should also consider the consequences for fellow trustees, and the charitable company, who will share liability for non-compliance, as it is an offence for a company to be run by an unverified trustee.
What it means for Charitable Companies
Charitable companies should prepare for mandatory identity verification by undertaking the following actions:
- Identify who will need to undertake identity verification
- Provide training on the changes and requirements of identity verification
- Encourage those who are eligible to complete identity verification on a voluntary basis prior to 18 November 2025
- Ensure anyone who files on behalf of the charitable company (such as a company secretary) undertakes identity verification in preparation for further requirements
- Review and ensure the list of trustees and PSCs with Companies House are up-to-date and correct
If you require assistance determining who is required to undertake identity verification, or further information on the changes, please contact schoolsupport@wslaw.co.uk.