Companies House Identity Verification for Non-Resident and Overseas Directors

When the Economic Crime and Corporate Transparency Act 2023 introduced mandatory identity verification for company directors, the requirement applied to everyone on the Companies House register — not just UK residents. For the many expats who hold directorships in UK companies while living abroad, and for the overseas directors of companies with UK branches, the practical question is not whether to verify but how to do so without being physically present in the UK.

The answer depends largely on what identity documents you hold. The process is genuinely straightforward for directors with biometric passports; it requires a different route for those without. This guide walks through both options and covers the specific OS VS01 requirement for overseas companies.

Who must verify and when

Identity verification is mandatory for:

• All directors of UK limited companies, LLPs, and other registered entities
• All Persons with Significant Control (PSCs) — anyone holding more than 25% of shares or voting rights, or with the right to appoint or remove a majority of the board
• All directors of overseas companies with a registered UK establishment

There are two separate deadlines depending on when you became a director:

• New directors appointed from 18 November 2025 onwards: must verify before their appointment can be registered at Companies House
• Existing directors appointed before 18 November 2025: must verify by 18 November 2026

The two verification routes

Companies House provides two routes to complete identity verification. The correct route for you depends primarily on whether you hold a biometric passport.

Route 1: Verifying through GOV.UK One Login

GOV.UK One Login is the government's identity verification service. For Companies House purposes, it uses the biometric chip embedded in modern passports to verify your identity without you needing to be present anywhere in the UK.

What you need

• A biometric passport — any country, as long as it has an NFC chip
• A smartphone capable of reading NFC — most modern smartphones from 2018 onwards
• The GOV.UK ID Check app, available on iOS and Android
• Proof of your current address — typically a bank statement or utility bill dated within the last three months

The process

1. 1
   Create a GOV.UK One Login account at gov.uk/one-login if you do not already have one. You will need an email address.
2. 2
   Download the GOV.UK ID Check app on your smartphone. This is separate from the general GOV.UK app and is specifically for identity verification.
3. 3
   Scan your biometric passport. Hold your phone flat against the back of the passport so the NFC reader can communicate with the chip. The app guides you through this step.
4. 4
   Complete the liveness check. Follow the prompts to take a short video or selfie that confirms you are the person in the passport. This is a standard facial recognition step.
5. 5
   Provide your address. You will be asked to confirm your current residential address. Have a recent bank statement or utility bill ready as supporting evidence.
6. 6
   Link your verified identity to Companies House. Once verified through GOV.UK One Login, you access Companies House services using your One Login credentials. Your Companies House personal code is generated at this stage.

Route 2: Using an Authorised Corporate Service Provider (ACSP)

If you do not hold a biometric passport — or if your passport has expired and you are awaiting renewal — you must use an authorised corporate service provider. ACSPs are UK-regulated entities registered with Companies House that are permitted to verify identities on behalf of directors and submit the results directly to the register.

ACSPs include formation agents, solicitors, accountants, and specialist compliance firms. Many offer fully remote verification services that can be completed without visiting the UK. The process typically involves:

• Submitting scanned copies of your identity documents (passport, national ID card, or other accepted documents)
• A live video call with an ACSP agent for identity confirmation
• Provision of proof of address
• The ACSP then submits your verified details to Companies House and provides you with your personal code

Fees vary considerably between providers — from around £30 to over £100 depending on the service level and how quickly you need the verification completed. If you used a formation agent to incorporate your UK company, they are often the most practical starting point as they already hold your company details.

Your Companies House personal code

Once identity verification is complete — by either route — Companies House assigns you a personal code. This is a unique alphanumeric identifier that belongs to you as an individual, separate from any company registration number.

The personal code is what you provide when:

• Registering a new company and confirming your directorship
• Being appointed as a director of an existing company
• Filing form OS VS01 for an overseas company (see below)
• Updating your personal details on the Companies House register

Keep your personal code safe. It does not expire along with any specific company registration — it is your permanent identifier across all Companies House filings. If you are a director of multiple companies, you use the same personal code for all of them.

OS VS01: identity verification for overseas company directors

Directors of overseas companies — foreign-incorporated entities that have registered a UK establishment — face an additional requirement. They must file form OS VS01 for each director, providing their Companies House personal code and confirming that identity verification has been completed.

The OS VS01 deadline

The deadline for existing overseas company directors to file OS VS01 is the anniversary of the date the UK establishment was opened — not the date it was registered. This distinction was clarified in a correction to the official guidance in December 2025. If your establishment opened on 12 June 2019, for example, your OS VS01 deadline is 12 June 2026.

New directors of overseas companies must verify before their appointment can be registered, following the same rule as directors of UK-incorporated companies.

Consequences of missing the deadline

For existing directors, failure to verify by 18 November 2026 carries serious consequences that escalate quickly:

• Criminal offence — non-compliance is a criminal offence under the Companies Act 2006 as amended by the Economic Crime and Corporate Transparency Act 2023. This is not a civil penalty matter — it is a potential prosecution.
• Blocked confirmation statement — a company whose directors have not verified cannot file its annual confirmation statement. The confirmation statement is a mandatory annual filing; failure to file it triggers a chain of compliance failures.
• Strike-off risk — if the confirmation statement cannot be filed, Companies House may treat the company as no longer active and begin strike-off proceedings. A struck-off company is dissolved, and its assets — including bank accounts, property, and intellectual property — pass to the Crown.
• Financial penalties — separately from criminal proceedings, Companies House can now issue civil financial penalties under its post-May 2024 powers. Read more in the Companies House financial penalties guide.

New directors: what applies from November 2025

If you are being appointed as a director of a UK company for the first time — or being appointed to a company you were not previously a director of — verification must be completed before the appointment is filed. The appointment notification cannot be registered at Companies House until your personal code is included in the filing.

This has a practical implication for anyone setting up a new UK limited company: completing identity verification is now part of the incorporation process, not something you return to later. Factor the verification step — and any ACSP wait times if you need that route — into your timeline before you submit the OS IN01 or IN01 registration form.

Checking your verification status

You can check whether your identity has been verified for Companies House purposes by signing into the Companies House online portal using your GOV.UK One Login credentials. The verification status will be visible on your account. If you used an ACSP, they should confirm once the submission has been processed — which typically takes a few working days after they complete their checks.

If your company's record at Companies House shows directors whose verification status is outstanding, this will become visible to anyone searching the public register as the November 2026 deadline approaches. Companies House has indicated it will contact directors directly via the company's registered email address as the deadline nears, but this notification is a courtesy — the legal obligation to comply sits with the director regardless of whether a reminder is received.

Act before the queue builds

Seven months sounds like ample time, and for most individual directors the verification process takes less than twenty minutes. The risk is not the process itself but the circumstances around it: a biometric passport that expired last year and has not yet been renewed, an ACSP with a backlog in the weeks before the deadline, or a non-biometric document that requires a more involved verification path. The directors who will find themselves scrambling in October and November 2026 are those who left the task until the deadline was close.

For expat directors managing UK companies from abroad, the GOV.UK One Login route genuinely removes most of the friction. A valid biometric passport, a compatible smartphone, and fifteen minutes is all that is required. The ACSP route is slightly more involved but equally accessible remotely. Neither route requires a trip to the UK, a visit to a government office, or any in-person step.

If you are uncertain whether you have already verified — perhaps because your company was incorporated recently and you completed verification as part of that process — check your GOV.UK One Login account. Your Companies House personal code will be visible there if verification is complete. If it is not, add it to your calendar now rather than in autumn.

Disclaimer: This guide provides general information about Companies House identity verification requirements. It does not constitute legal advice. Always verify current requirements at GOV.UK.