Companies House identity verification: your confirmation statement is the real deadline

If your firm is a limited company or an LLP, the individuals behind it — its directors or designated members, and its people with significant control — now have to verify their identity with Companies House. Identity verification became a legal requirement on 18 November 2025 under the Economic Crime and Corporate Transparency Act, and the twelve-month transition period that began on that date ends on 18 November 2026.

November 2026 is the date being circulated, and for most firms it is the wrong one to plan around. The obligation on an existing director bites at the company's next confirmation statement, and for a good number of practices that filing date has already passed or is weeks away. Existing people with significant control verify by an appointed day within the same twelve months. Anyone being newly appointed must verify before the appointment or the incorporation takes effect.

Who this catches in a law firm

• Directors of an incorporated practice. Every director of a recognised body or licensed body that is a limited company, fee earner or not.
• Designated members of an LLP. An LLP has designated members rather than directors, and the regime reaches them. Firms that think of themselves as partnerships rather than as registered entities are the ones most likely to miss this.
• Individual people with significant control. Typically anyone holding more than 25% of the shares or voting rights, whether or not they do any legal work.
• The non-lawyer spouse holding shares. This group gets missed because nothing in their year prompts them to think about Companies House — and in a law firm it carries a second consequence, dealt with below.
• Anyone about to be appointed. A merger completing with new directors on the day, a partner being admitted to the board, or a new company incorporated to take an acquisition — in each case the individual must verify before the appointment or the incorporation.
• The dormant service company nobody has thought about since it stopped trading. It still files a confirmation statement, and the confirmation statement is where an existing director confirms verification.

The non-lawyer shareholder point that only applies to law firms

Verification puts a spotlight on who owns the firm, and in a regulated practice that is not a neutral question. Under the SRA Authorisation of Firms Rules, a firm in which all managers and interest holders are legally qualified can be authorised as a recognised body. If a non-lawyer holds an ownership interest or is a manager, the firm cannot be a recognised body and must be authorised as a licensed body — an ABS — with its own approval requirements. Rule 9.1 requires SRA approval of any manager or owner.

So the spouse who holds 30% of the shares for tax reasons is simultaneously a person with significant control who has a Companies House deadline, and an interest holder who has an SRA authorisation consequence. Firms that put that shareholding in place years ago and have not revisited it should treat verification as a prompt to check both, not one.

An illustrative sequence

Take a two-director recognised body incorporated in 2015, with a confirmation statement date of 22 October and a third solicitor due to join the board on 5 January. The figures and dates are illustrative.

• Before 22 October 2026 — both existing directors need to have verified, because the confirmation statement is the filing at which an existing director confirms verification. The codes have to exist before the filing is prepared, not on the day it is due.
• Within the transition — both directors are also individual PSCs on their shareholdings, and verify in that capacity by the appointed day that falls within the twelve months.
• Before 5 January — the incoming director must have verified before the appointment. A completion or admission timetable that assumes the appointment can simply be filed on the day is wrong, and this is the point at which verification stops being administrative and starts holding up a transaction.

Notice that none of those three dates is 18 November 2026. That date is the end of the transition window for the population as a whole. What actually binds this firm is a confirmation statement in October and a board appointment in January, and both of them come first.

Why a law firm cannot treat this as a filing problem

What the rules actually say is narrow, and it is enough. A new director must verify before the appointment or the incorporation takes effect; an existing director confirms verification at the company's next confirmation statement; an existing PSC verifies by an appointed day within the twelve-month window that closes on 18 November 2026. So the constraint lands on the two things a law firm is least able to reschedule: a board change, and a filing date.

For most businesses a delayed appointment is an irritation. For an authorised body it reaches further, because the entity concerned is the one that holds the SRA authorisation, the professional indemnity policy, the lease, the client account mandate and the bank facility, and its management is approved by the SRA. A verification step nobody diarised is capable of holding up a merger completion or a partner admission that the rest of the firm has already planned around.

There is also a straightforward regulatory reporting angle. The SRA Code of Conduct for Firms requires firms to notify the SRA promptly of any change to information recorded in the register, and to notify promptly of material changes to previously supplied information about the firm, its managers, owners or compliance officers. Board changes made or delayed because of verification are exactly the kind of thing that needs to be reflected in both places.

What to do this week

• Verify. Use the identity verification service through GOV.UK One Login. It is free and it takes minutes with a passport or driving licence.
• Look up your confirmation statement date on the public register. That date, not November, is the director deadline.
• List every individual PSC for each entity, including anyone who holds shares but does no legal work, and confirm each of them has a code.
• Put verification into the merger and partner admission checklist, alongside SRA approval of new managers and owners. A separate SRA consultation launched on 19 June 2026 and closing on 17 August 2026 proposes requiring firms to notify the SRA when they merge with or acquire another firm, so that checklist is likely to grow rather than shrink.
• Do the dormant company too. It still files a confirmation statement, and that filing is where an existing director confirms verification.

This article is information about how the Companies House regime and the SRA authorisation rules fit together, not legal advice. The effect of a particular appointment, and whether a shareholding changes your authorisation category, are questions for the SRA's own guidance and a solicitor.

The wider structure question

Each year this regime adds a little more friction to holding a company: verification now, a public register that shows more than it used to, and more filing obligations attached to the individuals behind the entity. That is not a reason to unwind a company that earns its keep, but it belongs on the cost side of a structure comparison that has already moved with the dividend rise from 6 April 2026. The full comparison, including the SRA authorisation and insurance consequences, is on our LLP versus limited company page.

Whatever the entity, the Accounts Rules follow the authorised body and its managers — the underlying obligations are set out in our guide to the SRA Accounts Rules. If nobody is tracking confirmation statement dates and verification status for your entities, that is part of what we take on.