Approaching Start Date for Identity Verification Requirements: 18 November 2025
November 6, 2025
18 November 2025 is the start date for the new ID verification (IDV) requirements applicable to individuals who are directors of English companies, members of English LLPs, or who, as a matter of English law, are subject to registration requirements as people with significant control (PSCs). When it comes to overseas company directors, they are subject to the new IDV requirements only if the relevant company has an establishment in the UK registered with Companies House.
The following Companies House press release and blog include useful and accessible information about the phasing-in timeline and the way the ID verification process works. A few important points included in those materials:
- From 18 November, directors and PSCs will be able to check the Companies House register to see identity verification due dates for all their roles.
- Companies House will be contacting companies with guidance as to the steps to be taken by them in connection with the IDV requirements.
- Individuals who are subject to the IDV requirements are encouraged to verify their identities as early as possible—this can be done directly with Companies House (through GOV.UK One Login) or by using the services of an Authorised Corporate Services Provider (a list can be found here).
For the main categories of individuals to whom the IDV requirements start applying on 18 November 2025, the timeline is as follows:
| New directors and LLP members |
From 18 November 2025, individual directors and LLP members must have their identity verified before their appointment is notified to Companies House, i.e. within 14 days of their appointment. |
| Current directors and LLP members |
From 18 November 2025, individual directors and LLP members will have to complete the IDV process no later than the first occasion on which the relevant company or LLP delivers its confirmation statement to Companies House. |
| New PSCs |
If registered as PSCs after 18 November 2025, individuals have 14 days from their registration with Companies House to complete their IDV and submit to Companies House a statement confirming this. |
| Current PSCs who are also directors |
If an individual is already registered as a PSC on 18 November 2025 and is also a director of the relevant company, such PSC has 14 days from the company’s confirmation statement date to comply with IDV requirements. |
| Current PSCs who are not directors |
If an individual is already registered as a PSC on 18 November 2025 and is not a director of the relevant company, the PSC has 14 days from the first day of the PSC’s month of birth, e.g. until 14 December 2025 if the PSC’s date of birth is in December. |
This memorandum is a summary for general information and discussion only and may be considered an advertisement for certain purposes. It is not a full analysis of the matters presented, may not be relied upon as legal advice, and does not purport to represent the views of our clients or the Firm. Sevda Staykova, an O’Melveny partner licensed to practice law in England & Wales; Andrew Weiler, an O’Melveny partner licensed to practice law in New York and England & Wales; David Carter, an O’Melveny partner licensed to practice law in England & Wales; Braeden J. Donnelly, an O’Melveny partner licensed to practice law in England & Wales; Daniel Hobbs, an O’Melveny counsel licensed to practice law in New York and England & Wales; and Hannah Gong, an O’Melveny counsel licensed to practice law in England & Wales, contributed to the content of this newsletter. The views expressed in this newsletter are the views of the authors except as otherwise noted.
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