- 6 October 2026
Read time: 4 minutes
Summary: The first identity verification convictions mark a major shift in Companies House enforcement. They highlight that boards are responsible not only for their own compliance, but also for ensuring unverified individuals do not continue acting as directors. With key ECCTA deadlines approaching, governance professionals should treat identity verification as a board-level accountability issue and take steps now to ensure compliance.
On 16 September three directors became the first people to be convicted of identity verification offences brought by the Insolvency Service.
This prosecution is a significant milestone as it also highlighted that directors have responsibilities not only for their own compliance but also for ensuring unverified people do not continue acting as directors on behalf of a company.
Identity verification moves from compliance to enforcement
Jill White and Marc Dillon, directors of White (Reading Properties) Limited were convicted following White participating in board-level decision making and signing company accounts while remaining unverified. Dillon had verified his own identity but was prosecuted after failing to take reasonable steps to prevent White from continuing to act as a director without identity verification.
The third director Modinat Banjo delivered company accounts on behalf of J Isogony Apparel Limited while being unverified. Although the fines were small (from £80 to £307), the clear cost is a criminal record and the embarrassment of being named in a public press release.
Companies House for decades had little power to check the UK company details they held. The 2023 Economic Crime and Corporate Transparency Act changed that by giving it powers to inspect and challenge the information provided.
A central part of this change is identity verification, which requires directors and people with significant control in a company prove who they are. New directors have had to verify before starting a role since 18 November 2025. Existing directors and people with significant control have a 12-month transition period and must verify by the time of their company's next confirmation statement. With that transition period ending in November, many companies have already passed their deadline, and the rest may have only weeks left.
These headline convictions are part of a pattern of enforcement emanating from Companies House. These include 23 directors banned from running companies for a combined 70 years for persistent or serious non-compliance in August. Also, that month, Companies House started emailing firms whose directors or owners had not verified.
Plus, in September, seven companies were shut down by the High Court after investigators found they had filed accounts naming audit firms that had never audited them.
Another significant update is the Presenter measures. The ‘Presenter’ is essentially whoever submits documents to Companies House such as a Company Secretary. Under the new rules, that person will have to be identity-checked themselves, or be a registered filing firm (an ACSP, or Authorised Corporate Service Provider).
The Institute was concerned about the implementation timeline for this measure and gave feedback to Companies House on behalf of governance professionals. Companies House have now agreed that this requirement will start no sooner than November 2027 and organisations will get at least six months’ notice.
A further implementation that has been delayed is account filing changes. Companies will have to file accounts using approved software rather than the website or paper. Small companies will have to file their profit and loss account but can ask for it to be kept off the public record (the government is yet to set out how), and the slimmed-down "abridged" accounts option will no longer be available. This was originally slated for 2027 but is now going live on 1 April 2028.
Why boards need to take accountability seriously
While identity verification may seem like a personal admin task for many directors, governance professional know it is a board responsibility. The conviction of Dillon demonstrates that if you are aware that a colleague has not verified and you let them carry on, you can be prosecuted too. In these recent cases all three had been given several chances to comply so an accurate record of reminders is one protection against prosecution.
Companies House has said a common reason why it is sending warnings out to people who are both a director and an owner is that they only verify once, but they must give their personal code to Companies House twice, once for each role.
Governance professionals need to also manage the requirement for identity verification for directors, including trustees of charitable companies that are on long-term leave.
The Institute’s Governance in Absentia research found that directors on long-term leave for reasons such as illness, maternity or caring responsibilities remain legally responsible for their company.
Practical steps to prepare for what's next
Now
• Audit identity verification status for every director and PSC across the group, including subsidiaries and dormant companies, against each entity's confirmation statement date.• Check that anyone holding both roles has provided their personal code for each.
• Make verification a condition of appointment in your onboarding process and appointment resolutions.
• Agree a procedure, approved by the chair, for preventing an unverified director from voting, counting towards quorum or signing documents.
• Minute reminders and escalations so the board can evidence that reasonable steps were taken.
• Brief the board on directors' personal exposure for allowing an unverified colleague to act.
Before November 2027
• Map who presents filings for each entity, whether in-house staff or external providers.
• Confirm that in-house presenters will be verified, and that external providers are registered ACSPs. Check them against Companies House's fit and proper guidance.
Before April 2028
• Confirm that your accounts software, or your accountant's, can file in the required digital (iXBRL) format.
• Put the decision on publishing the profit and loss account to the board as a governance decision, not an administrative one.
Find out more: GOV.UK identity verification guidance and the CGIUKI September Technical Briefing.