Board Minutes to Document and Approve IDV of Existing Directors

In accordance with section 167M(2) of the Companies Act 2006 (introduced by the Economic Crime & Corporate Transparency Act 2023 (ECCTA)), a company will commit an offence if it allows a person who has not verified their identity to act as a director.

Important legal point: identity verification and the company’s offence risk (s.167M(2) CA 2006)

From 18 November 2025, UK company directors must verify their identity. There are different rules for new and existing directors. For existing directors, there is a 12-month transition period for compliance, tied to the timing of a company’s annual confirmation statement. This means the time available for existing directors to verify their identity may vary significantly depending on the date the company’s confirmation statement is due.

Companies House is encouraging all directors to verify their identity as soon as possible to avoid delays.

Use these board minutes to record the company’s approval and communications to existing directors

Although identity verification (IDV) is completed by each individual director, it may be useful for a company to keep documentary evidence that it has approved the approach and highlighted the need for all directors to verify their identity, given the obligation under section 167M(2). These template board minutes can be used for that purpose.

What these board minutes record

• That the IDV regime has come into force and the timing of IDV for existing directors.
• The methods by which a director may complete IDV.
• The unique identification code issued to a director once identity has been successfully verified.
• Confirmation that the directors are not disqualified under the updated directors’ disqualification regime.
• Confirmation that the company has communicated with its directors in relation to the IDV regime.

New directors: IDV must be completed before appointment

The timing of IDV for new directors is different and must be completed before their appointment.

How this fits within the ECCTA reforms

The ECCTA gives Companies House new and enhanced powers to help disrupt economic crime, and the IDV regime is a key component of this.

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