Director and PSC verification requirements

Director and PSC verification are often talked about as though they were the same requirement. They are not. Both have to verify, both use the same identity-check process, and both end up with a personal code - but the obligations attached to each role are different, the triggers are different, and the consequences of getting it wrong land in different places.

This is a working guide to what each role has to do, when they have to do it, and what specifically Companies House is checking.

What counts as a director

A director is anyone appointed to that role at Companies House, whether they run the company day-to-day or not. Non-executive directors are directors. So are directors of dormant companies, family-owned businesses, and single-shareholder companies where the owner is also the sole officer. If your name is on the register as a director, you verify.

Nominee arrangements do not exempt you. If the register lists you, you are the person Companies House expects to verify. Shadow directors - people who exercise director powers without a formal appointment - are also within scope, though enforcement in that area is more complex.

What counts as a PSC

A person with significant control is anyone who meets one of the PSC conditions: holding more than 25% of the shares, holding more than 25% of the voting rights, having the right to appoint or remove a majority of the board, or otherwise exercising significant influence over the company. A PSC does not have to be a director, and often is not.

Companies with corporate PSCs (an ultimate parent that owns another company) still have to identify the natural person at the top of that ownership chain. That individual verifies. The chain of nested companies does not shield the human owner from the requirement.

Where the two roles overlap

In most small UK companies, one person is both director and PSC. The verification requirement applies once to that person, not twice. The personal code that Companies House issues is attached to you, and it carries both roles.

This is a genuinely useful design. A founder who runs a limited company, holds 100% of the shares, and files their own accounts does not have to prove their identity three times. They verify once, get one code, and that code works everywhere their name appears.

What the check is actually looking for

Identity verification is not a background check. Companies House is not screening for creditworthiness, criminal record or business history. The single question is: are you the person the register says you are?

The check confirms three things. That the identity document you present is genuine and matches you. That the name and date of birth on the document match the entry against your name on the register. And that the address you supply as proof-of-address is current and belongs to you.

If the match is clean, the check finishes quickly. If your Companies House entry lists a slightly different spelling to your passport, or an address you no longer live at, the check pauses until the register is updated or the ID is corrected.

The PSC-specific pitfall

PSCs face one issue directors typically do not: their register entry may have been made by an accountant or formation agent years ago, with abbreviations, missing middle names, or an old address. That entry has to match the identity document you verify with. If it does not, you have to file a change to the PSC register first, wait for it to update, then attempt verification.

The clean approach is to pull your PSC entry from Companies House before you start, compare it side-by-side with your passport, and correct any discrepancies before you begin the identity check. It costs nothing and it prevents a rejected verification.

When the deadline actually falls

For existing directors and PSCs, the trigger is your company’s next confirmation statement date. You need to be verified before that filing goes in. Miss the window and the confirmation statement itself is held up, which puts the company into late-filing territory.

For new appointments, verification has to happen before the appointment is recorded. You cannot be listed as a director of a UK company from the day the regime is fully in force without a verified identity behind the listing.

Enforcement, honestly

The public conversation about ECCTA sometimes reads as though every unverified director will be prosecuted the day after their deadline. In practice, Companies House expects most people to comply and is building enforcement gradually - starting with rejected filings and financial penalties, escalating to disqualification only where there is a pattern of deliberate non-compliance.

That is not a reason to leave it. Every rejected filing costs the company time and creates a public record of non-compliance that future lenders, business partners and auditors will see. The point of the regime is that the register becomes trusted. Getting verified is the way you earn a place in it.