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Trustees, Members and Governing Rules

Identity Verification for Charitable Company Trustees

Use this section if your charity is a company limited by guarantee and you need to deal with Companies House identity verification for its trustees. This section is not relevant to a charitable incorporated organisation (CIO) or an unincorporated charity, because identity verification is a company law requirement and applies to the trustees of a charitable company in their capacity as directors.

Why does identity verification affect charitable companies?

The Economic Crime and Corporate Transparency Act 2023 introduced a requirement for company directors and certain other people connected with a company to verify their identity with Companies House. Trustees of a charitable company are its directors, so each of them is caught. The Note to CCLBG Charity Trustees - Summary of Key Issues under ECCTA summarises what the Act means for a charitable company and its trustees.

What documents are in this section?

The Letter to CCLBG Trustees re ID Verification tells existing trustees what they need to do. The Trustee Identity Verification Form (Charitable Company Limited by Guarantee) collects the information the charity needs to keep track of each trustee's verification. The Confirmation by Trustee of Identity Verification (Charitable Company Limited by Guarantee) and the Charitable Company Limited By Guarantee Letter to Trustee Re Confirmation of Identity Verification record that verification has been completed. The Consent to Act CCLBG Trustee's Confirmation (Identity Verification Compliant) is a consent to act for a new trustee that builds in the verification confirmation.

The board minutes and written resolution for appointing a new trustee in a way that takes account of identity verification are in the Appointments and Resignations: Corporate Charities section. A checklist of the wider changes made by the Act is in the General Administration and Ongoing Compliance section.

Identity Verification for Charitable Company Trustees is part of Charity. Just £38.50 + VAT provides unlimited downloads from Charity for 1 year.

Frequently Asked Questions

Do charity trustees really have to verify their identity with Companies House? +
Only where the charity is a company: CCLBG trustees are directors, so identity verification has applied to them since 18 November 2025. Trustees of CIOs and unincorporated charities are outside the regime entirely because Companies House does not regulate those structures. If your charitable company also has people with significant control, they verify too. The Note to CCLBG Charity Trustees in this section summarises the position board-side.
How does a new CCLBG trustee actually verify their identity? +

Once, personally, before the appointment is filed: either directly with Companies House through GOV.UK One Login, or via an authorised provider such as a solicitor or accountant registered as an ACSP. They receive a personal code that links their verified identity to the appointment. Verification is portable across all their company roles. The consent to act template is in this section. The appointment resolution is in the Appointments and Resignations: Corporate Charities section.

Our existing trustees were appointed years ago. When is their verification deadline? +
Their due date is the charity's first confirmation statement date after 18 November 2025, so every existing trustee is covered by 18 November 2026 at the latest. Check each trustee's due date on the Companies House register, chase confirmations well before the statement is due and record them. The letters to trustees and confirmation forms in this section run exactly that chase, and the summary note briefs the board once.
What happens if a trustee does not verify in time? +
The charity has a problem on both sides: an unverified new trustee cannot properly be notified to Companies House, and an existing trustee who continues to act past their due date without verifying commits an offence, with the company exposed too. Treat non-response as a governance issue: chase in writing, record the follow-up and escalate to the board before the confirmation statement is due. If a trustee cannot or will not verify, take advice on their position promptly.
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