Bulk and white-label Companies House identity verification

Verifying one director is a ten-minute job. Verifying forty is a project, and the difficulty is almost never the identity check itself. It is chasing people, sequencing them against a filing date, and knowing which of them will fail the digital route before they try it. These are the five patterns we are built for.

1. Accountancy practices. You have a client book of owner-managed companies, each with one or two directors who are also the PSCs, and confirmation statement dates spread across the year. Companies House says that over 10,000 accountants, solicitors and formation agents have already registered as ACSPs (Companies House blog, 11 December 2025), and if you are not one of them you need somebody who is.
2. Solicitors and notaries. Corporate teams handling appointments, share transactions and restructurings where a new director cannot be appointed until they are verified, because new directors must verify before appointment (GOV.UK).
3. Company formation agents. Incorporation now requires verification first, so every new company is gated on it. Companies House recorded 815,277 new incorporations in the year to March 2026 and 192,287 in April to June 2026 alone (Companies register activities 2025–26).
4. Company secretarial teams. A group with fifteen subsidiaries, overlapping boards and one confirmation statement cycle. One unverified director rejects the filing (Companies House), so the work is coordination rather than verification.
5. Corporate groups with overseas boards. Non-executive and overseas directors are the hardest to reach and the most likely to hold documents that do not suit the free route. Our overseas fee is a flat £175 with no time-zone surcharge, and our country pages set out the document position country by country.

The legal position is that each person must complete their own identity check personally. Nobody can verify on somebody else's behalf, and no ACSP can batch-process a spreadsheet of names into personal codes. What can be industrialised is everything around the check, and that is where the time goes.

• Scoping. We take your list of individuals and their roles, split it by residence and by role, and identify which deadline applies to each person: next confirmation statement for existing directors, before appointment for new ones, 14 days after the confirmation statement date for a PSC who is also a director, and the first 14 days of the birth month for a PSC who is not.
• Document triage. We tell you in advance who is likely to pass the digital route and who needs a two-document check, before anybody wastes an attempt. This is the single biggest time saving at volume.
• Sequenced invitations. Secure verification links issued in the order your filing dates require, not all at once.
• Chasing. We follow up the people who have not completed, which is the task in-house teams find most expensive.
• Filing and collation. We file each verification with Companies House as authorised agent and hand you a single register of who is verified and which 11-character code belongs to whom.

The output for each person is one code that covers all of their appointments, because the code is personal to them and not to the company, and a director of multiple companies verifies once and reuses the same code. In a group with overlapping boards this reduces the total number of verifications considerably, and it is worth mapping before you start rather than after.

Every professional firm with a company client base has faced the same decision since 2025: register as an ACSP and do this in-house, or outsource it. Both are legitimate. GOV.UK describes an ACSP as an agent, such as an accountant or solicitor, who files on behalf of others, requires each ACSP to be supervised by a UK anti-money-laundering supervisory body, and states that registered ACSPs must be based in the UK. The public list is published and maintained by Companies House, last updated 20 August 2026.

Registering makes sense if verification volume is high and continuous and you already carry the supervision and record-keeping infrastructure. Outsourcing makes sense if your volume is concentrated around confirmation statement dates, if the compliance overhead is disproportionate to the fee income, or if you simply do not want the file-keeping obligation. Of all verifications completed to 31 March 2026, 783,000 went through ACSPs against 3 million through GOV.UK One Login (Annual Report and Accounts 2025–26), so the assisted channel is a real but minority route, and it is growing into the November 2026 end of the transition.

Where you would rather your clients did not see a third party at all, we act white-label. You keep the client relationship and the correspondence style; we carry out the identity check and make the filing, because only a registered ACSP can verify and file on another person's behalf. We wrote about the mechanics of this in corporate service providers and bulk director verification.

Identity verification became a legal requirement on 18 November 2025, and Companies House is careful to say that this is not a deadline but the start of a 12-month transition period. That transition ends in November 2026. Companies House expects to have verified 6 to 7 million individuals by then, and had reached about 3.8 million by 31 March 2026 (Annual Report and Accounts 2025–26). Somewhere between two and three million verifications therefore have to happen in the closing months of the transition.

For a firm with a client book, that arithmetic is the whole argument for starting now. The capacity problem is not ours or Companies House's; it is yours, because every one of your clients whose confirmation statement falls in the autumn will need their directors verified in the same few weeks. The free Post Office route takes about 15 days, which is a long time to discover a problem in October.

Before scoping a volume exercise it is worth restating precisely who is in scope and who is not yet, because getting this wrong at volume is expensive.

GOV.UK lists the people who must verify as a director, the equivalent of a director, which includes members, general partners and managing officers, a director of an overseas company registered in the UK, a person with significant control, and anyone registering as an Authorised Corporate Service Provider. People who file on behalf of a company, limited partnerships, corporate directors, corporate LLP members and officers of corporate PSCs will be required to verify at a later date.

Identity verification became a legal requirement on 18 November 2025. Companies House is explicit that this date is not a deadline in itself; it marks the start of a 12-month transition period that ends in November 2026, by the end of which Companies House expects to have verified 6 to 7 million individuals (Annual Report and Accounts 2025–26). Your own deadline sits inside that window and depends on your role:

• Existing directors: by the company's next confirmation statement date.
• New directors: before appointment, and at incorporation for a new company.
• Directors of overseas companies registered in the UK: by the anniversary of the UK establishment's registration.
• A PSC who is also a director: within the 14-day period starting the day after the confirmation statement date.
• A PSC who is not a director: within the first 14 days of their birth month.

Once you have verified, Companies House issues an 11 character personal code. It is personal to you and not to your company, and if you are a director of multiple companies you only need to verify once and then use the same code for every appointment.

At volume these consequences compound, because a single unverified individual can hold up filings across several companies.

Companies House states that it is unlawful for a director to act as a director without completing identity verification, and that the offence arises under section 167M of the Companies Act. Three enforcement routes are available: criminal prosecution, referral to the Insolvency Service, and financial penalties. Prosecution may lead to criminal conviction, director disqualification and fines, and non-compliance can be annotated on the public register for anyone to see.

There is also an immediate, practical consequence that arrives long before any enforcement action. All directors need to verify before the company's next confirmation statement is filed, otherwise the filing will be rejected. The campaign guidance puts it more bluntly still: without verification you will not be able to make any filings for your company or start a new company. For most people that rejected filing, not the prospect of prosecution, is what makes this urgent.

Our published fees are £125 for a UK-resident individual and £175 for an individual resident overseas, both all-inclusive with no VAT and no add-ons. For volume work, send us four things and we will come back with a quote and a schedule:

1. How many individuals in total, split into directors, PSCs and LLP members or general partners.
2. How many of them are resident outside the UK, and roughly where.
3. The confirmation statement dates you are working towards, or the appointment or incorporation dates if the work is transactional.
4. Whether you want the service white-labelled under your own brand or delivered directly to the individuals.

• Corporate service providers and bulk director verification
• UK cities we cover
• Overseas directors, by country
• Our full ACSP service
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