Companies House ID verification: how to clear your client backlog before (and after) 18 November
If your practice files confirmation statements, you’ve probably already had the conversation: “What’s a personal code?” “I’m sure I did that.” “Can’t you just do it for me?” Multiply it by every director and PSC on your client list and you get the job that will fill a lot of practice diaries this autumn.
5 min read · For UK accountancy firms
The Companies House identity verification transition year ends on 18 November 2026. Here’s where things stand, what the first prosecutions changed, and a simple way to work through your client base.
Where things stand
- 68% of the 9.9 million directorships on the register had a verified identity linked as at 23 September, with 1,817,822 overdue.
- PSCs were further behind: 56% verified and 1,837,060 overdue.
- Overdue numbers are rising. They went up by roughly 325,000 directorships and 370,000 PSC roles between June and September.
Figures compiled from Companies House data by Jacques Malan of Xama and shared on AccountingWEB. Some overdue directorships belong to dormant companies, but even excluding those, more than a million directorships at live companies are overdue.
Three things the first prosecutions changed
On 16 September three directors were fined at City of London Magistrates’ Court in the first Insolvency Service prosecutions for ID verification offences. The fines were small: £166 and £307 plus costs. But they were criminal convictions, and the cases make three things clear:
- A verified director can still be convicted. Marc Dillon had verified. He was prosecuted for failing to stop his unverified co-director acting.
- Unverified directors are signing accounts. The other director took part in board decisions and signed company accounts while unverified.
- One missing code blocks the confirmation statement. Both were also convicted over a confirmation statement that wasn’t filed on time.
Don’t forget the PSCs
PSC verification is a separate step with its own timetable:
- PSCs provide their code through a separate Companies House service, within a 14-day window.
- Directors who are also PSCs must provide the code twice: on the confirmation statement and again as a PSC.
- For PSCs who aren’t directors, the window starts on the first day of their birth month.
- Non-compliance letters usually go to the PSC’s home address, so your practice may never see them.
A four-group triage
Build one list with one line per person per role, and sort it:
| Group | Who | What to do |
|---|---|---|
| Red | Overdue, code not linked | Act this week. Check for default letters; there are 28 days to make a representation. |
| Amber | Due in the next 60 days | Start now. The Post Office route alone can take two to three weeks. |
| Green | Verified and linked for every role | Store the code safely and record it. |
| Grey | Dormant companies | Decide with the client whether to verify or dissolve. |
Keep “verified but not linked” as its own status. A code sitting in a client’s inbox doesn’t make them compliant.
Choose a route and put a price on it
Clients can verify for free through GOV.UK One Login, or your firm can register as an Authorised Corporate Service Provider (ACSP) and verify them directly. That means meeting Companies House’s identity verification standard, keeping records of each check for seven years, and having your firm’s name shown on the register next to each person you verify. Either way, it’s work, and it belongs in the engagement letter with a fee attached. Agents who file for clients will also have to register as ACSPs, from no earlier than November 2027, so the decision is coming either way.
Running the campaign from your client portals
The verification itself takes minutes. The time goes on asking, reminding, collecting codes from email threads and keeping track of who has done what. That’s the part MyDocSafe takes off your team’s plate:
- One request, every client. Use Request Information on a Portal Group to send a short form to every client portal at once: who has verified, which route they used, their personal code for each role, and an upload field for the Companies House confirmation email.
- Codes out of the inbox. Personal codes and confirmation emails arrive in the client’s encrypted portal, not in a forwarded email, with a full audit trail.
- Agree the fee in the same place. Send the engagement letter update for e-signature in the same portal, so the scope and fee are agreed before the work starts.
You end up with one place showing who has responded and what they’ve sent, instead of a spreadsheet and a shared inbox.
Start with the list
18 November is the day the list turns from “due” to “overdue”. Building it now takes an afternoon. Building it in December means doing it with default letters on the desk and January on the way.
Run your ID verification chase from client portals
See how practices send one request to every client, collect personal codes securely and agree the fee in the same place.
Sources: Companies House verification figures compiled by Jacques Malan of Xama, AccountingWEB Any Answers, 22 June and 23 September 2026 (June-to-September changes are our calculation). Insolvency Service press release on the first identity verification prosecutions, GOV.UK, 17 September 2026. GOV.UK guidance on identity verification for directors and PSCs, Companies House’s non-compliance approach, and the Post Office verification route (updated 22 September 2026). GOV.UK guidance and Registrar’s rules 2025 on becoming an Authorised Corporate Service Provider. ICAEW, August 2026, on the timing of ACSP registration for agents who file.