Companies House director verification: your real deadline

Director identity verification became a legal requirement on 18 November 2025. For a director already in post on that date, the deadline is your own company's next confirmation statement — a rolling, company-specific date. There is no single national deadline by which every director must be verified.

What is director identity verification?

A requirement that an individual's identity is verified before they act as a director. Section 167M of the Companies Act 2006, inserted by the Economic Crime and Corporate Transparency Act 2023, provides that an individual must not act as a director unless their identity is verified, and that the company must ensure the same.

Verified directors hold a Companies House personal code. For companies already on the register, the confirmation statement is the vehicle through which that code is supplied — the identity verification statement is delivered at the same time as the next confirmation statement.

Which directors does this apply to?

Every director — but by two different routes, and the route decides the deadline.

Directors already in post before 18 November 2025 go through the transitional route in regulation 4 of S.I. 2025/1118. Their verification statement rides on the company's next confirmation statement. This page's main deadline is theirs.
Directors appointed on or after 18 November 2025 get no transitional relief at all. Their position is covered separately below, and it is stricter.

The routes apply per individual, not per company. A company can easily have directors on both.

When is my director identity verification deadline?

The last day of the delivery period for your company's next confirmation statement. That is a company-specific, rolling date driven by your own review period — not a date shared with any other company.

Regulation 4(2) requires the company to deliver an identity verification statement in respect of the individual at the same time as it delivers its next confirmation statement during the transitional period. Regulation 4(6) is what makes that the operative date rather than merely the filing occasion: the section 167M prohibition does not apply to the individual until the day after the company complies with its confirmation statement duty, or — if it does not comply — the day after the last day of the delivery period.

So the protection runs out when your confirmation statement window closes, whether or not you filed.

What if the director leaves before the confirmation statement is delivered?

The duty falls away. Regulation 4(4) disapplies it: the regulation 4(2) duty "does not apply if the individual is not a director of the company at the time mentioned in that paragraph", and regulation 4(4)(b) disapplies the carried-forward duty in regulation 4(3) in the same terms.

So an individual who was a director before 18 November 2025 but has ceased to hold office by the time the relevant confirmation statement is delivered is owed no identity verification statement by the company under regulation 4 — even though they were in post when the transitional route started running.

What if the company's confirmation statement was already overdue on 18 November 2025?

The relief ended much earlier. Regulation 4(7) provides that a company with an already-overdue confirmation statement on 18 November 2025 lost the transitional relief on the earlier of two events: the date it complied, or the end of the day on 2 December 2025. Regulation 4(8) defines when a statement counts as overdue for this purpose.

For those companies the transitional window was a fortnight, not a year, and it has long since closed.

What is 17 November 2026?

The last day of the statutory transitional period — and a boundary, not a deadline.

Regulation 4(9) defines the transitional period as "the period of 12 months beginning with 18th November 2025". Because the period begins with 18 November 2025, that day is day 1, and the period ends on 17 November 2026 — not 18 November 2026. The inclusive construction moves the end date back by one day, which is a distinction worth getting right if you are working to it at all.

Is there a national deadline by which every director must be verified?

No. This is the most commonly misstated point in the regime, and stating it wrongly creates a false deadline.

Regulation 4(3) carries the duty forward expressly: if the company fails to deliver a confirmation statement during the transitional period, it must still deliver the identity verification statement at the same time as it delivers its next confirmation statement, whenever that falls. A company that files nothing inside the window still owes the statement afterwards.

So 17 November 2026 is the closing edge of the regulation 4(2) window, not a longstop for verification. The real bite in the meantime is section 167M itself — under regulation 4(6), a defaulting company's directors lose their relief the day after their delivery period ends, which for most companies is long before November 2026.

What about directors appointed on or after 18 November 2025?

No transitional route, and no delivery window of any kind. Section 167M applies to them directly: they must not act as a director unless their identity is verified.

There is no grace period, no confirmation-statement-linked window, and no later date to count down to. Verification has to be in place at or before the moment the individual begins acting. This is a standing control rather than a calendar item — which also means it is the case a deadline tracker cannot rescue you from, because there is no date to remind you of.

What happens if a director acts while unverified?

Two enforcement routes exist, and they are alternatives rather than a stack.

The criminal route. Section 167M(3): an individual who acts as a director while unverified commits an offence. Section 167M(4): where a company fails to ensure that an unverified individual does not act, an offence is committed by the company and by every officer in default — and a shadow director is treated as an officer for this purpose. Section 167M(5) sets the penalty on summary conviction: in England and Wales, a fine with no stated maximum; in Scotland or Northern Ireland, a fine not exceeding level 5 on the standard scale, plus a daily default fine not exceeding one-tenth of level 5 for continued contravention.

How much is the registrar's financial penalty?

It is a formula, not a published figure. Section 1132A of the Companies Act 2006, inserted by section 104 of the ECCTA 2023, empowers the registrar to impose a financial penalty where it concludes, beyond reasonable doubt, that a person engaged in conduct amounting to a relevant offence.

Section 1132A(4) requires regulations to ensure the maximum does not exceed £10,000. Regulation 7(1) of S.I. 2024/445 then provides that a financial penalty must not exceed the maximum fine a court could impose for the same offence in the jurisdiction where it was committed and, in any event, must not exceed £10,000.

The penalty may be a fixed amount, a daily rate, or both — with regulation 7(2) permitting a daily rate only where the offence carries a daily default fine in that jurisdiction. Unpaid penalties carry interest under regulation 7(5), at the rate the registrar directs or, absent a direction, the Judgments Act 1838 section 17 rate.

Can both penalties apply at once?

No. Section 1132A(5) makes them mutually exclusive in both directions: no financial penalty may be imposed where proceedings for the offence are ongoing or have led to conviction, and no proceedings may be brought where a financial penalty has already been given for that conduct.

Does an unverified director's decision become invalid?

No, and the Act says so directly. Section 167M(6): "The only consequences of contravening subsections (1) and (2) are the offences provided for by this section (so that, for example, a contravention does not in any way affect the validity of an individual's acts as a director)."

Contracts signed and decisions taken by an unverified director stand. The exposure is the offence, not the unwinding of company acts.

What changed recently?

Section 167M came fully into force on 18 November 2025. That is the commencement day the whole regime keys off: it decides which directors get the transitional route, it starts the twelve-month transitional period ending 17 November 2026, and it is the date against which the regulation 4(7) overdue-filer rule was tested.

Confirmation statement — the filing this statement rides on, and the source of your actual deadline
People with significant control: register and notification — the parallel PSC verification routes
Annual accounts and late filing penalties — the other Companies House annual deadline
Pillar hub: ECCTA and Companies House reform (placeholder)
Companies House deadline checker — enter your company number to see the confirmation statement date this deadline follows

Companies House director verification: when your deadline actually falls