Companies House has published guidance on its approach to non-compliance with the identity verification (IDV) regime. The guidance sets out the enforcement action available to Companies House, which includes financial penalties, referral to the Insolvency Services and prosecution. However, it stresses that enforcement actions will be used proportionately, in accordance with the nature and seriousness of any non-compliance.

Companies House guidance can be accessed here.

From 18th November 2025, it is unlawful for a director to act as a director without completing IDV. A company may also commit an offence if one of its directors is not verified and persons with significant control (PSCs) who do not verify their identities may also be committing an offence. 

There are 2 steps to IDV:

• completing a successful IDV check (and getting a unique identifying code called a Companies House personal code); and
• providing an identification statement to Companies House to confirm an identity is verified (including supplying the personal code).

Failure to file an IDV statement is in breach of the legislation. If an individual director breaches IDV requirements, the whole company is also breaching requirements.

Companies House states that its approach to enforcement includes four broad categories:

• informing people of their obligations
• nudging and guiding
• dealing with non-compliance
• addressing fraud and criminal activity

Informing people of their obligations

Companies House will email companies directly before filing their annual confirmation statement to tell them they must provide IDV statements for each of their directors by their filing deadline.

For formal enforcement correspondence about IDV, Companies House will normally send a letter to the company’s service address. For PSCs, they will usually send non-compliance letters to their residential address.

Nudging and guiding people to comply

Companies House states that whilst it cannot IDV users directly, it will help people to comply with IDV requirements in a variety of ways, including by providing guidance online and answering queries, signposting and offering advice through their contact centre. For example, Companies House may suggest using an Authorised Corporate Service Provider (ACSP) to IDV.

Depending on the circumstances and if Companies House receive a representation, they may pause pursuit of non-compliance for a temporary period.

Enforcement action

If users do not comply with IDV requirements by their due date, Companies House will send them a default letter setting out the offence of not complying and explaining that enforcement action may be pursued without further notice.

Companies House have three main routes for enforcement action:

• prosecution through court 
• referral to The Insolvency Service
• financial penalties.

Companies House states that it will use the most suitable enforcement approaches by assessing amongst other things, the nature of non-compliance, previous patterns of non-compliance, evidence available to them, value for money, and whether other agencies are acting (or considering action) in relation to the matter.

Companies House will use their strongest powers where there is evidence of aggravated, fraudulent or criminal offences. In serious cases, Companies House are more likely to prosecute, which could result in a criminal conviction, director disqualification and fines. Companies House are likely to consider non-compliance to be ‘serious’ if a person or company has committed three or more offences over a five-year period.

Where directors continue to act without IDV, Companies House will send the company a letter outlining the offences. Companies House may refer those continuing to act without IDV to the Insolvency Service.

Companies House may issue financial penalties at company or individual officer level where directors or PSCs fail to comply with IDV requirements.

Other enforcement methods available to Companies House include:

• directing a company to take an action or refrain from taking an action
• annotating the register for public transparency
• issuing financial penalties to companies and PSCs
• pursuing a civil case
• pursuing criminal prosecution
• disqualifying directors
• court order – ordering a company to file or provide documents and accounts
• referring a case to other agencies who use their powers such as The Insolvency Service
• prosecuting companies and removing defaulted companies from the register.

Representations

If there are extenuating circumstances for Companies House to consider, a representation can be made in writing within a time frame prescribed by Companies House. Representations received outside of the timeframe will not be considered. Companies House will decide whether to accept the representation and this decision will be final. After the time frame has passed, Companies House may pursue enforcement action without further notice.

Companies House is likely to accept representations where there is evidence that circumstances were exceptional and related to the due date and where it would be disproportionate to pursue enforcement activity at that time. The example given is of a company experiencing serious IT failure when the identity verification statement was due with no other way to complete the task.

If Companies House accepts the representation, enforcement action will be paused, usually for up to two months to give the company time to comply with identity verification requirements or rectify matters affecting their compliance.

Companies House, however, makes very clear in its guidance that ultimately a director (or equivalent) MUST verify their identity to continue to act and remain lawful. New directors must verify their identity to be appointed as a director (or equivalent), or to incorporate a new company.

PSC due date extension

The Registrar of Companies has discretion to extend the IDV due date for a PSC by up to 14 days. By extending the due date, the PSC is not non-compliant and remains compliant. However, if the PSC does not submit their IDV statement before the extended due date, they will commit an offence and Companies House will send a default letter setting out that offence. After two digital extensions, Companies House will refer further requests to an examiner to consider along with supporting evidence.