ECCTA status update – Updated Information on IDV Requirements and Non-Compliance Enforcement
Updated Information
November 2025 saw the latest wave of significant implementation under the Economic Crime & Corporate Transparency Act 2023 (ECCTA). Most importantly this included the commencement of mandatory identity verification (IDV) for all new and existing directors and people of significant control (PSCs) as well as the abolition of most statutory registers.
All UK company directors and PSCs must now verify their identity and obtain and use a personal code to prove this by the deadline applicable to their circumstances.
The ECCTA is a landmark legislation designed to give Companies House new and enhanced powers to help disrupt economic crime and the IDV process is a key component of this.
Many of the changes as they affect SME private companies and their interaction with Companies House are now in force. Our information has been updated to reflect this.
Note that Companies House has also stated its approach to non-compliance with IDV requirements. Information has been added in relation to this. Companies House has stated that their approach will be based on first, informing people of their obligations, followed by "nudging and guiding" individuals to comply, and then acting for non-compliance (which includes the option to prosecute through the courts, refer to the Insolvency Service and issue financial penalties). Companies should be clear that ultimately a director (or equivalent) MUST verify their identity to continue to act and remain lawful and new directors must verify their identity to be appointed as a director (or equivalent), or to incorporate a new company.
The following information has been updated:
- Changing Role of Companies House.
- Implementation Timetable Update November 2025.
- Overview of the Identity Verification Regime.
- How IDV works.
- Who Needs to IDV.
- IDV of Directors.
- IDV of PSCs.
- Third Party Filings & IDV.
- IDV Action Points.
- IDV Non-Compliance Enforcement.
- Maintenance of Company Registers.
As a reminder, there are many templates on our site that relate to the changes introduced under the ECCTA and may be used to ensure appropriate compliance.
The contents of this Newsletter are for reference purposes only and do not constitute legal advice. Independent legal advice should be sought in relation to any specific legal matter.