When existing directors must verify their identity

Q: What do people get wrong?

Treating 18 November 2025 or 17 November 2026 as the date. The working deadline is each company's own confirmation statement date. Leaving it to the last day. Companies House emails companies before the statement is due, and one director's delay stops the whole filing. Verification by Post Office or through an ACSP can take days. Forgetting the PSC role. A director who is also a PSC provides the code again in the PSC service, in a 14 day window starting the day after the confirmation statement date. See when PSCs must verify. Assuming a late filing only costs a penalty. It can also expose every unverified director to prosecution, as explained in what happens if a director does not verify. Company directors can protect the business against the cost of an HMRC check with tax investigation insurance, which pays up to £100,000 of accountant's fees with Solar Protect. Read how our cover works or get a quote. See also: CS01: the confirmation statement explained.

A director who was already in post on 18 November 2025 does not have a fixed calendar deadline. Their identity must be verified, and their Companies House personal code given, in the company’s next confirmation statement, and the company must deliver that statement within 14 days after the end of its review period. Because review periods last 12 months, every company has a review period ending within the 12 month transitional period that runs from 18 November 2025 to 17 November 2026.

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Where does the transitional rule come from?

The general rule in section 167M of the Companies Act 2006 is that nobody may act as a director unless their identity is verified. For people who were already directors, regulation 4 of the Economic Crime and Corporate Transparency Act 2023 (Commencement No. 6 and Transitional Provisions) Regulations 2025 (S.I. 2025/1118) phases this in:

it applies to any individual who became a director of a company before 18 November 2025 (regulation 4(1));
the company must deliver an identity verification statement for that individual at the same time as it delivers its next confirmation statement during the transitional period (regulation 4(2));
the transitional period is the 12 months beginning with 18 November 2025 (regulation 4(9)).

Companies House made the same point when the rules started: 18 November 2025 was not a deadline but the start of a 12 month transition. Equivalent transitional rules for existing LLP members are in S.I. 2025/1116; see LLP filings at Companies House. For an overseas company, Companies House guidance says it must confirm that all its directors have verified by the anniversary of its UK establishment’s registration.

How do you work out the actual date for your company?

Use the confirmation statement rules in section 853A. Each review period is 12 months, starting with the day of incorporation for the first and then running from the end of the previous one. The company must deliver its confirmation statement before the end of 14 days after the review period ends, and the confirmation date cannot be later than the last day of the review period.

So the practical deadline for an existing director is the last day for filing the company’s first confirmation statement due after 18 November 2025. Both the confirmation date and the filing deadline are shown on the company’s page on the Companies House register. Regulation 4(6) protects the director and company from the section 167M offence until the day after the company files, or, if it does not file, the day after the last day of the delivery period.

A company that already had an overdue confirmation statement on 18 November 2025 had much less time. Under regulation 4(7) and (8) its protection ended on the earlier of the day after it filed with verification statements and the end of 2 December 2025.

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What must the confirmation statement confirm?

Under section 853A(1)(b)(i) a confirmation statement confirms that the company has delivered, or is delivering with it, all the information it is required to deliver for the confirmation period. Regulation 4(5) widens that to include the duty to deliver director verification statements, so a company cannot properly confirm while any director’s statement is missing.

Companies House guidance on the confirmation statement says that on the next statement you must:

give the Companies House personal code for each director; and
tick a statement confirming that each director has verified their identity.

It also says Companies House will not accept the confirmation statement until all directors have verified. Before filing, any changes to directors, the secretary, PSCs, the registered office address and the registered email address must already have been notified, and the company must state that its intended future activities are lawful. The online fee is £50 and a paper CS01 costs £110. The wider filing duty is in the confirmation statement explained.

What about a director of several companies?

They verify once and use the same personal code, but the code has to be given in each company’s confirmation statement, so each directorship has its own deadline. A director of five companies with different confirmation dates will have five dates in the transitional year, and each company’s filing is blocked until that director’s code is supplied.

Can the company change the timing by filing early or late?

Not in a way that helps. Filing early simply brings the requirement forward: the statement still needs codes for every director, and under section 853A(6) the next review period then runs from the day after the new confirmation date. The confirmation date cannot be pushed past the end of the review period, because section 853A(4) prevents it.

If a company fails to deliver any confirmation statement during the transitional period, regulation 4(3) carries the duty over: the verification statements must accompany the next confirmation statement it does deliver. That does not excuse the late filing, and the director loses the protection from the section 167M offence once the delivery period has ended.

What if a director leaves before the statement is filed?

Regulation 4(4) says the duty does not apply to someone who is no longer a director when the confirmation statement is delivered. The resignation or removal must be notified to Companies House first, within 14 days, as described in resigning as a director. A director who carries on running the business after being taken off the register may still be acting as a director.

A worked timeline

Illustration only.

Company	Confirmation date	Filing deadline	Position at 19 October 2026
Alder Ltd	31 March 2026	14 April 2026	Should already have filed with codes for every director. If it did not, its directors have been at risk of the offence since 15 April 2026.
Birch Ltd	31 October 2026	14 November 2026	Directors must verify now. Codes go in the statement filed by 14 November.
Cedar Ltd	31 October 2026, but files early on 20 October	Filed 20 October	Codes needed on 20 October. Next review period starts 21 October 2026.

A director who sits on Alder and Birch uses one code for both, but the Birch filing cannot be made until the code is entered there too.

What do people get wrong?

Treating 18 November 2025 or 17 November 2026 as the date. The working deadline is each company’s own confirmation statement date.
Leaving it to the last day. Companies House emails companies before the statement is due, and one director’s delay stops the whole filing. Verification by Post Office or through an ACSP can take days.
Forgetting the PSC role. A director who is also a PSC provides the code again in the PSC service, in a 14 day window starting the day after the confirmation statement date. See when PSCs must verify.
Assuming a late filing only costs a penalty. It can also expose every unverified director to prosecution, as explained in what happens if a director does not verify.

Company directors can protect the business against the cost of an HMRC check with tax investigation insurance, which pays up to £100,000 of accountant’s fees with Solar Protect. Read how our cover works or get a quote.

Related Accountapedia entries

Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.