Where the same individual is both a director and a person with significant control (PSC), completing identity verification once may not be enough. The individualâs personal verification code must be linked separately to each capacity in which they are registered.
This means someone may be correctly verified as a director but still appear non-compliant as a PSC because the additional registration step has been overlooked.
If youâre both a director and a PSC of the same company, the personal code must be submitted twice:
Where youâre an existing PSC but not a director, the code must be submitted within a verification window that runs from the 1st to the 14th day of your birth month each year. If youâre a new PSC you normally need to submit your personal verification code within 14 days of being added to the Companies House register.
Treating your director filing as being sufficient â or not providing your PSC verification code within the right 14-day window – can leave your PSC record non-compliant even though identity verification itself has been completed.
This is complex â and failing to comply can lead to a financial penalty and a public warning note on the registry. You can manage this yourself but you may feel more assured getting help from an Authorised Corporate Service Provider (ACSP).
Identity verification is fast becoming a transaction-readiness issue, not simply a filing task.
Appointments of new directors, changes in control, acquisitions, group reorganisations and holding company restructures often involve board and PSC updates at or immediately after completion. Discovering at the last minute that an incoming director or PSC has not completed the necessary steps can put avoidable pressure on already tight timetables.
The practical response is straightforward:
There are more changes to come beyond individual PSCs. One will require each corporate PSC that is a registrable relevant legal entity (RLE) to nominate a ârelevant officerâ. This is an identifiable individual whose identity has been verified and whose status must be maintained while the RLE remains registered.
The aim is to ensure a traceable, verified individual stands behind every corporate PSC. For straightforward UK groups, identifying that person may be simple. For multinational groups, private funds, layered holding arrangements and complex ownership chains, it may be less clear – particularly where several entities and jurisdictions sit between the UK company and the ultimate controlling individuals.
Organisations with corporate PSCs should start mapping these structures and considering who could fulfil the role now, rather than waiting for final implementation guidance.
Further reforms are also expected, including confirmation statement requirements to identify the PSC exemption being relied upon, additional obligations relating to registrable PSCs and RLEs and continued restrictions on corporate directors.
Taken together, these measures reinforce Companies Houseâs shift from a passive recipient of information to an active gatekeeper focused on the accuracy, reliability and integrity of the UK corporate register.
Bridgehouse delivers expert entity management and statutory compliance services â including director and PSC identity verification checks. You can get more information and help from Louisa Christofilou using the form below.
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