The Name That Checks Out: Keeping Companies House Identity Verification Filing-Ready

A company register records presence. A director is named, a PSC is disclosed, and the public file says that these people are connected to the company. Since identity verification became a standing requirement, that presence needs to be backed by something more than a typed name. The person behind the entry must be verifiable when a filing is made, a director changes, or a confirmation statement falls due. The Adsum idea – to be genuinely present – is useful here. A name on a register means little if the person behind it cannot be verified when it counts.

Who needs a verified identity

Start with the statutory registers, not with memory. Pull the current list of directors and people with significant control (PSCs), and check whether the company has any relevant officers connected to corporate PSCs or other entities. Limited liability partnership members may also fall within the scope. The practical question is simple: which human beings sit behind the entries that Companies House expects to be verified?

Directors are the obvious group, including non-executive directors and any alternate directors who are appointed. PSCs are equally important, even where they are not directors. A person can hold both roles, and that should be recorded clearly rather than assumed. Company secretaries are not currently part of the director verification requirement, but they often hold the operational thread, so they should know where the evidence sits.

New appointments need particular care. A new director should be verified before the appointment is filed, with the personal code available for the filing. Existing directors should be checked before the next confirmation statement and before any change that requires a filing. The routine should not depend on someone remembering an email from months ago.

Two routes, one outcome

There are two main routes to verification. The direct route is for the individual. The person uses their GOV.UK One Login to prove their identity, typically with photographic identification and a liveness check, and receives a Companies House personal code. This route suits directors who are comfortable managing their own account and who can act promptly when asked.

The authorised agent route is through a Companies House authorised agent, sometimes called an ACSP. An authorised agent can verify identity on behalf of clients and may also file on their behalf. This can be useful for overseas directors, for boards that need to verify several people in a short period, or where an existing professional adviser already handles company secretarial work. The route is not a shortcut around responsibility. The individual still needs a personal code, and the company still needs to know that verification has happened.

Before relying on an agent, check that the firm is actually listed as an authorised agent. Ask how long verification takes, how identity documents will be handled, and where the evidence will be retained. Do not assume that every accountant or formation agent offers this service. Agree who chases the individual, who confirms the outcome, and who updates the company’s own records.

A simple verification register

A verification register does not need to be complicated. It needs to be accurate, restricted, and reviewed. Keep it separate from the public register and treat it as an internal control. A spreadsheet is adequate for many smaller companies, provided access is limited and the file is backed up.

Useful columns include: full name; role or roles; date of appointment; verification status; route used; date verified; whether a personal code is held; where the code is stored; where supporting evidence is held; next review date; and the person responsible for chasing. Do not record the personal code itself in an open spreadsheet. Record that it exists and where it is held securely.

A simple red, amber, green status works well. Green means verified and code held. Amber means verification started or an agent instruction issued. Red means not started, or a new appointment has been made without a code. Review the register monthly and immediately before any confirmation statement. Cross-check it against the PSC register so that a PSC who is not a director is not overlooked.

The filing gate

Make verification a gate, not an afterthought. Before a confirmation statement is filed, export the current officer and PSC lists, compare them with the verification register, and chase anything that is amber or red. If an authorised agent is filing, send the list early enough for the agent to check it. The filing should not be the first time anyone notices that a director has never completed verification.

For appointments, add a verification step to the appointment checklist. No personal code, no filing. For resignations, update the register and retain the record in line with the company’s retention policy. For changes of name or identity details, check whether the existing verification still matches the person’s current identity documents. If there is doubt, seek guidance rather than assuming that an old verification covers a new situation.

A routine that holds

Identity verification is not a project with an end date. It is part of the ordinary rhythm of company administration. Give one person ownership, review the register on a fixed cycle, and report exceptions to the board or management team. Keep the evidence trail short but clear: who checked, when, and what was found.

The test is not whether the register looks tidy. The test is whether a director change, a confirmation statement, or an agent’s request can be handled without a scramble. A verified name is a present name in the practical sense. That is the standard worth holding.