Over the last couple of years, you may have noticed an increasing number of communications from Companies House about changes to company law, identity verification and what you need to do as a director.
These changes arise from the Economic Crime and Corporate Transparency Act 2023 (ECCTA), which has given Companies House greater powers and introduced new requirements for companies, directors and people with significant control (PSCs). The reforms have been introduced gradually and Companies House has described them as the biggest changes to the organisation since corporate registrations began in 1844.
For many owner-managed businesses, the changes may initially have felt like another administrative exercise. However, with mandatory identity verification approaching the end of its first year and the first directors now having been prosecuted and fined for failing to comply, there is good reason to take another look at the changes and make sure you have done everything you need to do.
What has actually changed?
One of the main aims of ECCTA is to improve the accuracy and reliability of the information held at Companies House.
Historically, Companies House largely served as a record of information. Its role is now becoming significantly more active. Since March 2024, it has had greater powers to query and reject information which it suspects is incorrect or fraudulent, remove inaccurate information from the register and share information with law enforcement agencies and other public bodies. However, there are also a number of more practical changes which affect the day-to-day administration of ordinary companies.
Registered office address
Every company must now have an “appropriate address” as its registered office.
In practical terms, correspondence sent to the registered office should be expected to come to the attention of somebody acting for the company and there should be an acknowledgement of delivery. Companies can no longer use a Royal Mail PO Box, or equivalent service, as their registered office address. Companies House also has stronger powers where a company fails to maintain an appropriate address.
If your registered office is provided by your accountant or another professional adviser, it is still worth checking that the arrangement remains in place and that you know how correspondence will be passed on to you.
Registered email address
Companies must also provide a registered email address to Companies House. Unlike your registered office, this email address is not displayed on the public register. It is used by Companies House to communicate with the company about its filings and compliance.
The practical point is simple: make sure somebody is actually monitoring it.
An email address belonging to a former employee, an old accountant or an inbox which nobody regularly checks could mean important Companies House correspondence is missed.
Confirmation statements and lawful purpose
Companies must now confirm that their intended future activities will be lawful when filing their confirmation statement. A similar statement is required when a new company is incorporated.
Although this may appear to be little more than another box to tick, it forms part of the wider change in approach towards ensuring that companies and the information recorded about them are legitimate and accurate.
Have you verified your identity yet?
For most owner-managed companies, identity verification is probably the most significant practical change.
From 18 November 2025, identity verification became compulsory for new directors and PSCs as part of new incorporations and appointments. At the same time, a 12-month transition period started for existing directors and PSCs to comply with the new requirements. For existing companies, directors’ identity verification is linked to the company’s confirmation statement.
For many small and family businesses, the same people are shareholders, directors and PSCs. It is therefore particularly important that each individual understands the requirements which apply to them rather than assuming that the company, their accountant or another director has dealt with everything on their behalf.
Identity verification can be completed directly using the Companies House service or through an Authorised Corporate Service Provider.
If you have already completed the identity verification process, you will have received a personal code from Companies House. Keep that code safe, as it is personal to you rather than to any particular company and is used in connection with your verified identity and company roles.
Is Companies House actually enforcing the new rules?
Until recently, it may have been easy to view the reforms as something which Companies House was still gradually introducing. That is becoming an increasingly risky approach.
On 16 September 2026, the Insolvency Service successfully brought the first prosecutions for identity verification offences. Three company directors were fined following proceedings at City of London Magistrates’ Court. The facts provide a useful warning for directors.
Jill White continued to act as a director while unverified, including taking part in board-level decision making and signing company accounts. Modinat Banjo also continued acting as a director while unverified and signed and delivered company accounts. Both were ultimately prosecuted and fined. Perhaps even more importantly for companies with several directors, Marc Dillon had verified his own identity. However, he was prosecuted for failing to take reasonable steps to prevent another unverified director from continuing to act, despite being aware of the requirement.
The message is therefore wider than simply “have I verified myself?” Directors should also consider whether their fellow directors are entitled to continue acting. The Government’s announcement expressly warned that directors have responsibilities both for their own compliance and for ensuring that unverified individuals do not continue acting as directors on behalf of the company.
In the cases resulting in the first prosecutions, the directors had been given multiple opportunities to comply before enforcement action was taken. However, Companies House and the Insolvency Service have made clear that identity verification is not optional and directors who continue to act without complying risk investigation and prosecution.
What do I need to do now?
If you are a director of an owner-managed company and have not yet looked properly at the Companies House reforms, now is a good time to carry out a basic health check.
1. Check your company’s Companies House record
Start by looking at the company’s entry on the Companies House register.
Are the directors correct? Are the PSC details correct? Is the registered office up to date?
If something is wrong, do not assume it does not matter simply because the inaccurate information has been on the register for some time. Companies House now has significantly greater powers to query and remove information, and improving the accuracy of the register is one of the central purposes behind the reforms.
2. Check that all directors have completed identity verification
Do not assume that your accountant, another director or the company has somehow completed this for you.
If you have not verified your identity, check your deadline and deal with it as soon as possible.
If there are several directors, it is also sensible to make sure that every director understands their obligations. The first prosecutions demonstrate that simply having complied personally does not necessarily mean a director can ignore another director’s failure to do so.
3. Check your PSC requirements
If you own or control the company as well as being a director, you may also be a person with significant control.
Identity verification requirements extend to PSCs as part of the reforms, so do not simply check your position as a director and assume that is the end of the exercise.
4. Check your registered email address
Make sure the registered email address remains current and that someone is actively monitoring it.
Companies House itself has emphasised the importance of keeping the registered email address correct and ensuring that emails are monitored as the reforms continue to be rolled out.
5. Check your registered office
Make sure that your registered office remains an appropriate address and that correspondence received there will actually reach you.
This is particularly important where your registered office is provided by somebody else, such as an accountant or other professional adviser.
6. Review your wider company records
Finally, use the Companies House exercise as an opportunity to check the company’s wider corporate records.
For example:
- Does the register of members accurately record who owns the shares?
- Have all share transfers been properly documented?
- Have share certificates been issued and retained?
- Have changes in ownership or management been properly recorded?
- Do your Articles of Association still suit the way the business is run?
- If you have a Shareholders’ Agreement, does it still reflect the current ownership and intentions of the shareholders?
It is surprisingly common for an owner-managed business to know who everyone believes owns the company, only to discover that the paperwork does not quite tell the same story.
When did you last carry out a company health check?
For many small and owner-managed businesses, Companies House compliance is something that gets attention once a year when the confirmation statement is due and very little thought for the remaining 364 days. The recent reforms make that approach increasingly risky.
They also provide a useful opportunity to look beyond Companies House and ask whether your company’s legal documents and internal records properly reflect the business as it operates today.
If your company has been running for several years, has changed shareholders or directors, issued or transferred shares, or simply has company documents which have not been reviewed for some time, a corporate health check can identify potential problems before they become much more difficult to resolve.
At Scott Bailey, our Corporate and Commercial team can review your Companies House position alongside your company’s internal records, Articles of Association and shareholder arrangements and advise on any steps required to bring them up to date. Contact us to arrange a consultation.
