Identity Verification Implementation Checklist for Businesses | ECCTA

Preparation Phase

• Review the ECCTA requirements and Companies House guidance
• Identify all individuals who must verify their identity:
  • Directors
  • Persons with Significant Control (PSCs)
  • LLP members or general partners
  • Individuals who file documents (from 2026)

• Assign internal responsibility for managing the verification process (e.g. Company Secretary or Compliance Officer)

Data Collection & Communication

• Compile a list of affected individuals with contact details
• Communicate the verification requirement and deadlines to each individual
• Provide instructions on how to verify (GOV.UK One Login, Post Office, or via ACSP)
• Ensure individuals have access to valid ID documents (passport, driving licence, etc.)

Verification Process

• Choose verification method(s):
  • GOV.UK One Login
  • Post Office service
  • Authorised Corporate Service Provider (ACSP)

• Track verification progress for each individual
• Record verification confirmation codes securely

Compliance Monitoring

• Set internal deadlines ahead of Companies House requirements
• Update company registers and confirmation statements with verified status
• Monitor Companies House filings for rejection due to non-verification
• Schedule periodic reviews to ensure ongoing compliance

Documentation & Reporting

• Maintain a secure log of verified individuals and methods used
• Keep copies of communications and verification confirmations
• Prepare for audits or regulatory checks

Contingency Planning

• Identify fallback options for individuals unable to verify online
• Engage an ACSP for complex or international cases
• Prepare to update filings or appointments if verification fails

Please be aware that no guidance has yet been issued on the verification of corporate directors/trusts & PSC Relevant legal entities.

Please note that this content is not intended to give specific technical advice. It is designed to highlight some of the key issues rather than provide an exhaustive explanation of the topics. Professional advice should always be sought before action is either taken or refrained from as a result of information contained herein.

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