Verifying identity of People with Significant Control

As with directors, People with Significant Control (PSCs) will be required to verify their identity. However, there are some key differences in relation to the verification process of PSCs as opposed to directors.

New PSCs

Once PSCs are identified by a company, the information can be submitted to Companies House (CH) for the relevant PSCs to be added to the register. 

Individual PSCs will have a 14-day period after registering in which to verify their identity. 

Relevant Legal Entities (RLEs) will have a 28-day period in which to verify and for RLEs, one ‘relevant officer’ must be verified. The verified relevant officer must be a natural person. If the RLE is an entity with affairs managed by its members, the verified person must be a member, and for anyone else, the verified person must be an officer (most likely to be a company director). 

PSCs can be notified to CH in either the statement of initial significant control (SISC) on formation or in a notice delivered to CH after formation. 

If a PSC is an individual, the SISC or notice may, but does not have to include a statement that the individual’s ID is verified. If the PSC is a legal entity, the SISC or notice may but does not have to include two statements – one specifying the name of the relevant officer, who is an individual whose ID is verified, and another by the relevant officer confirming that they are the relevant officer.

For those PSCs that remain unverified, CH will follow up with them to obtain verification and the relevant statements. The company does not need to do anything further.

This optionality means companies need to think about the timing of PSC verification and if PSCs are to ID verify only when contacted by CH, PSCs will need to be alerted by the company that this is the process that they are adopting.

Advance verification/Already verified

PSCs may have chosen to verify in advance of registration, in the same way as directors. In addition, some PSCs will already have a verified account with CH (for example if they are a director of the company in question or another company), if this is the case, they will not need to reverify and the registration will link automatically to their existing account. The PSC will then be flagged as “verified” on the companies register.

Not already verified

If the PSC doesn’t have a verified CH account, CH will notify the PSC and the company of the requirement that the PSCs must verify their identity. Provided the PSC provides all relevant information within the set period, the PSC will be flagged as “verified” on the companies register. However, if the PSC within the set period after registration does not verify their identity, CH will annotate the register to show that the PSC is “not verified”. The PSC will have committed a criminal offence and may be liable to a civil penalty. It is also expected that if PSCs are not verified within a short time after the incorporation of a company, they will commit a criminal offence.

Existing PSCs

From 8th April 2025, Companies House allows individuals to voluntarily verify their identity. There will then be a 12 month transition period during which existing PSCs must verify their identity. This is expected to start in Autumn 2025. As with directors, PSCs are well advised to voluntarily verify their identity as soon as possible.

Non-Compliance

The consequences of non-compliance with the ID verification requirements will depend on the circumstances. However, failure to verify identity could result in criminal proceedings, civil penalties, the incorporation or registration of a new company being rejected, the company being unable to file statutory filings and the public register being annotated to show the PSC’s status as “unverified”.