All UK companies (including UK subsidiaries of overseas companies) and UK branches of overseas companies are subject to the new identity verification rules under the Economic Crime and Corporate Transparency Act 2023.

For UK companies, all directors and PSCs (persons who have significant control of the company) must have their identity verified (IDV).

For UK branches, all directors (but not PSCs) must also be IDV’d.

UK Companies

All directors must be IDV’d before the company can file its annual confirmation statement.  The company will not be able to file its annual confirmation statement if any of its directors have not been IDV’d.

All PSCs (who are also directors) must be IDV’d within 14 days of the filing of the annual confirmation statement.

If a PSC is not also a director of the UK company, separate rules apply – in these circumstances, the PSC must be IDV’d within 14 days of the beginning of their month of birth.  For example, if a PSC was born on 20 January 1970, they must be IDV’d no later than 14 January 2026.

UK Company

IDV deadline

Director only

Before filing of annual confirmation statement

Director and PSC

(1)     As a director, before filing of annual confirmation statement

(2)     As a PSC, within 14 days of filing of confirmation statement

PSC only

Within 14 days of the beginning of their month of birth

 

UK Branches of Overseas Companies

All directors must be IDV’d on or before the anniversary of the date the branch was first opened.  For example, if a branch was first opened on 23 March 2006, the directors must be IDV’d by 23 March 2026.

UK Branch

IDV deadline

Director

The first anniversary (on or after 18 November 2025) of the establishment of the branch.

PSC

Not applicable

 

More to come?

If a PSC (such a majority shareholder) is another corporate entity, it is likely that one officer of the PSC will also be required to be IDV’d.  However, these rules are not yet in force and we will update you once they do become law.

How 3CS can help

As an Authorised Corporate Service Provider, 3CS can carry out the relevant IDV checks and arrange for the appropriate filings to be made at Companies House.  Please contact your usual 3CS team member if you would like to use our services. 

Keith McAlister

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3CS Corporate Solicitors Ltd


London Office
English (United Kingdom)
60 Moorgate, London EC2R 6EJ
+44 (0)20 4516 1260
info@3cslondon.com
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Tokyo Office
Japanese
Level 20, Marunouchi Trust Tower – Main
1-8-3 Marunouchi Chiyoda-ku, Tokyo, 100-0005
+81 (0) 3 5288 5239
info@3cstokyo.com
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Registered in England & Wales | Registered office is 60 Moorgate, London, EC2R 6EJ
3CS Corporate Solicitors Ltd is registered under the number 08198795
3CS Corporate Solicitors Ltd is a Solicitors Practice, authorised and regulated by the Solicitors Regulation Authority with number 597935


Registered in England & Wales | Registered office is 60 Moorgate, London, EC2R 6EJ
3CS Corporate Solicitors Ltd is registered under the number 08198795
3CS Corporate Solicitors Ltd is a Solicitors Practice, authorised and regulated by the Solicitors Regulation Authority with number 597935