Academy Trusts: New ID verification requirements with Companies House
Identity verification is a new legal requirement at Companies House for directors (i.e. trustees), persons with significant control (PSC) and company secretaries. The changes were brought in to help deter people intending to use companies for illegal purposes. Identity verification will be a mandatory requirement from 18 November 2025.
Regardless of appointment date, all the above individuals will need to verify their ID by law. The deadlines are slightly different depending on whether you were appointed before or after 18 November 2025, so please review all the information below carefully.
Ways to verify identity
- Using the ‘Verify your identity for Companies House’ service
This service uses UK One Login to verify your identity. It is free of charge. This process is designed to be completed in minutes once you’ve setup your account. - Using an Authorised Corporate Service Provider (e.g. accountant or solicitor)
You can ask an Authorised Corporate Service Provider (ACSP) to verify your identity on your behalf. You will need to provide them with official documents as evidence and they will likely charge a fee.
What happens once verification is complete?
When you have successfully verified your ID, you’ll get a unique identifier known as a ‘Companies House personal code’. The code is personal to you, not your company or a company you work for. Keep this safe.
We recommend all active directors, PSCs and company secretaries verify their ID as soon as possible.
See the next section below which explains what you need to do with your code depending on who you are.
When you need to verify and provide your code
Directors (i.e. trustees) – existing appointments before 18 November 2025
If you were appointed before 18 November 2025, this guidance is relevant to you. Once you have verified your ID you will be sent a ‘Companies House personal code’. Keep hold of this as it will be requested as part of your academy trust’s next confirmation statement after 18 November 2025.
From our experience the governance professional or CFO usually deals with the confirmation statement for an academy trust, so liaising with them will be key. It maybe a few months until your confirmation statement is due so keep your code safe. You will be able to use your personal code for other companies where you are an appointed director too.
Directors (i.e. trustees) – new appointments from 18 November 2025
If you become a director after 18 November 2025, you’ll need to provide it as part of your appointment filing. Ensuring new directors complete the ID checks before the appointment form is filled out will be key as identity must be verified before they can be appointed.
Person with significant control (PSC)
A PSC within an academy trust is an individual who controls the trust based on specific conditions. As academy trusts have no shareholders, the rules therefore apply to the members of the trust.
An individual can be a PSC if they meet one or more of the following conditions:
- Holds more than 25% of the company’s shares
- Holds more than 25% of the company’s voting rights
- Has the right to appoint or remove a majority of the board of directors
- Has “significant influence or control” over the company, which is determined on a case-by-case basis
This guidance is slightly more complicated for PSCs. When you must complete the ID verification and provide your code depends on your situation. If you need further guidance on this as a Price Bailey client please contact our Academy Helpdesk ([email protected])
If you are an existing PSC (before 18 November 2025):
- If you are a director/trustee and a PSC of the same academy trust: as a director you must follow the step above, in addition, as a PSC, you must provide your personal code using a separate service within 14 days of your academy trust’s confirmation statement date. This service will be available when the requirement comes into force on 18 November 2025.
- If you are a PSC but not a director/trustee of the academy trust: you must provide your personal code within the first 14 days of your birth month. For example, if your date of birth is 22 January, your 14 day period will begin on 1 January. This service will be available when the requirement comes into force on 18 November 2025.
If you become a PSC - after 18 November 2025
You can provide your personal code when you’re first added to the Companies House register, or within 14 days of being added. Ensuring new PSC complete the ID checks before their appointment will be key as identity must be verified beforehand.
What happens if you do not verify
It is a mandatory requirement from 18 November 2025 and must be completed in line with the guidance above. If you do not comply with identity verification requirements on time, you will be committing an offence and may have to pay a financial penalty or fine.
Closing thoughts
The new identify verification regime is an important step forward under The Economic Crime and Corporate Transparency Act 2023, to improve transparency and reduce fraud. We recommend all active directors, PSCs and company secretaries verify their ID as soon as possible.
For further support or tailored advice regarding your audit and risk committee, please contact our team using the form below.
We always recommend that you seek advice from a suitably qualified adviser before taking any action. The information in this article only serves as a guide and no responsibility for loss occasioned by any person acting or refraining from action as a result of this material can be accepted by the authors or the firm.
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