The ID Verification Process

It is proposed that there will be two types of ID verification:

• direct verification via Companies House (CH);
• an indirect route through an Authorised Corporate Service Provider (ACSP).

Verifying ID direct with CH

If a person is verifying directly with CH, it is an online service (the user will need to create an account with CH), which will link a person with a primary identity document. This could for example, be a passport or driving licence. The person undergoing verification will take a photograph or scan of their face and the identifying documents. The two will be compared, using likeness matching technology, and the photo ID validated. If successful, the person will be notified that their identity has been verified in a matter of minutes. Primary ID documents may also be checked against government databases as part of the ID checking process.

Alternative methods will be available for individuals without photographic ID and digitally assisted/non-digital ID verification will be available for users who cannot use the digital ID verification system.

Note that the White Paper says that although this method of ID verification is direct with CH, the ID verification process will be outsourced to an identity service provider.

Verifying through an ACSP

The alternative to verifying directly with CH is that a verification statement can be made on the individual’s behalf and delivered to CH. This statement will be made by an ACSP, who will confirm to CH that it has verified an individual’s ID. 

ACSPs are intermediaries such as accountants, legal advisers, and company formation agents. They can be individuals, bodies corporate or unincorporated. They MUST be registered with a supervisory body for anti-money laundering (AML) purposes. They therefore already have an existing obligation to carry out customer due diligence checks on behalf of all their clients. ID verification will build on these existing checks. It is expected that an ACSP will need to be UK based. The checks that ACSPs will make will need to be at least as stringent as CH checks. Further details will be set out in Regulations.

ACSPs must register with CH (online) and demonstrate that they are supervised for AML purposes. If an individual, they apply as such (after being ID verified themselves), if a corporate body or other legal entity/partnership etc, their application must be delivered by a relevant officer (director, partner etc). The relevant officer of an ACSP does not need to be ID verified. CH will check that the ACSP is known to them and appropriately supervised. 

Note that ACSP’s can verify IDs and file documents/information at CH on behalf of others. An ACSP will therefore be able to make a notification to CH of a new director (or PSC) at the same time as issuing the relevant verification statement.