Accountants, Law Firms and Corporate Groups: Bulk Director and PSC Identity Verification

If you run an accountancy practice, a law firm, a company secretarial function, or a corporate group with several subsidiaries, Companies House identity verification isn't a one-off task you complete for yourself — it's a recurring operational problem across dozens or hundreds of directors and PSCs, each with their own confirmation statement date, their own documents, and their own risk of falling through the cracks. This article sets out how firms in that position actually manage it, and how we work with practices that need volume, not just a single application.

Why this is genuinely a different problem at volume

Under the Economic Crime and Corporate Transparency Act 2023, the identity verification duty attaches to each individual — every director, PSC, LLP member and general partner named on the register must complete their own check. Companies House confirms that a personal code is "personal to you, not your company," so there is no shortcut that verifies a group of people as a batch in a single check — each person's identity must still be individually established to the required standard. What changes at volume isn't the underlying legal requirement; it's the coordination problem of tracking dozens of individual confirmation statement dates, PSC 14-day windows, and document types across an entire client base or group structure, and making sure none of them slips.

How Companies House expects agents to operate

Firms acting for multiple clients register once as a Companies House authorised agent — an ACSP — rather than needing separate authorisation per client. Companies House's own account of the registration process confirms that "once an ACSP registration has been completed, a digital account and a unique identity number will be provided," after which "other employees of the ACSP can then be added to the account" and are permitted to carry out services, including identity verification checks, on the firm's behalf without each of them needing to verify separately (Companies House). To register, a firm must be supervised in the UK by an Anti-Money Laundering (AML) supervisory body and pay a registration fee, with the registration itself completed by someone in a senior role who verifies their own identity through GOV.UK One Login as part of that process.

This is exactly the infrastructure Director Personal Code operates under as a registered ACSP, and it's what makes volume work practical: one authorised account, one compliance framework, applied consistently across every individual check we run for your clients or your group.

What a volume arrangement actually looks like

When a firm brings us a batch of directors or PSCs to verify — whether that's a client list from an accountancy practice, a portfolio of subsidiary boards from a corporate group, or a cohort of new appointments from a law firm's company formation team — the process is the same six-step standard Companies House requires for every individual, run consistently across the batch rather than reinvented case by case:

• A single point of contact. Rather than each individual director dealing with us separately, your firm has one named contact managing the batch, tracking status, and escalating anything unusual.
• Consistent document handling. The same compliance checklist and document rules apply to every person in the batch, so outcomes are predictable and defensible if ever questioned.
• A shared view of progress. You can see which individuals in your batch have completed their check, which are pending, and which need a nudge — useful when you're managing confirmation statement deadlines across dozens of client companies with different filing dates.
• Individual checks, still done properly. Each person still personally completes their own identity check — per GOV.UK's verification standard, checking that "the person is real" and that they "physically match the photograph" cannot be delegated or batched away, and nor should it be.

Audit trail and record-keeping — built for scrutiny

Firms managing verification for clients are inevitably managing risk on their clients' behalf too, so the audit trail matters as much as the check itself. Companies House's identity verification standard requires records to be kept for seven years from the date the identity check is completed, covering copies of the documents checked, evidence of the checks completed, and records of any failed attempts. We apply this same seven-year retention consistently across every individual verified through a volume arrangement — so if a regulator, auditor, or the client itself ever needs to see how and when a given director or PSC was verified, there is one consistent record to point to, not a patchwork of informal notes across different staff members or different points in time.

Referral and white-label style working relationships

Not every firm wants to become its own ACSP. Registering directly means taking on the AML supervision requirement, the registration fee, and the ongoing responsibility for meeting the Companies House standard yourself, including the risk that non-compliant checks can lead to Companies House suspending or stopping the firm from acting as an authorised agent. Many accountancy practices, law firms and company secretarial providers prefer instead to refer their clients' verification needs to an established ACSP like Director Personal Code, under a straightforward working relationship: you remain your client's primary adviser, we handle the verification workstream discreetly in the background, and your client experiences a smooth, professionally managed process without ever needing to know (or care) which firm is running the technical check behind the scenes.

Group companies and multiple directorships across subsidiaries

Corporate groups face a specific version of this problem: the same individual may sit as a director across several subsidiaries, each with a different confirmation statement date. The good news here is structural — Companies House confirms that a person "only needs to verify their identity once" and then reuses the same 11-character personal code across every appointment they hold. The coordination challenge for a group secretariat is not re-verifying the same director repeatedly; it's making sure that single code is correctly provided against every relevant company's own filing, on that company's own schedule, and that no subsidiary is left exposed because a shared director's code was recorded against one entity but never propagated to the others.

Onboarding a batch: what we need from you

1. A list of individuals — names, roles (director/PSC/LLP member), and the companies each is attached to, so we can map deadlines correctly.
2. Residency status for each person — UK-based or overseas, since this determines both document requirements and our fee tier (£125 UK-resident, £175 overseas, all-inclusive, no VAT, per person).
3. Your preferred point of contact for status updates and escalations.
4. Confirmation of the working relationship — whether you want us liaising directly with each individual, or working exclusively through your firm as intermediary.

From there, each individual receives their own secure verification step (digital or, where needed, a scheduled video appointment), we apply our compliance review, and we submit each Identity Verification Statement to Companies House as authorised agent — with your firm kept informed throughout rather than left waiting for a final answer.

A note on fees at volume

We keep pricing simple rather than tiered by volume in a way that obscures the total cost: £125 per UK-resident director and £175 per overseas director, all-inclusive, no VAT, whether you're bringing us one person or fifty. For firms handling recurring verification needs across a client base, this predictability matters — you can quote or budget for a batch without negotiating a bespoke rate card each time.

Key takeaways

• Identity verification is always an individual duty — there is no single check that verifies a group of people at once.
• Firms register once as an ACSP and can add employees to that account without each employee re-verifying.
• A volume arrangement gives you one point of contact, consistent document handling, and a shared view of progress across a batch.
• Records are kept for seven years per individual, giving a consistent audit trail across your whole client base or group.
• A single personal code covers all of a person's appointments — the coordination challenge is making sure it's provided for every relevant company.
• Firms who don't want to register as their own ACSP can refer verification work to us under a straightforward working relationship.