On 16 September 2026, the UK saw its first convictions for breaking the Companies House ID verification rules. The Insolvency Service and Companies House announced them the next day. Until now, the rule mostly existed on paper. But enforcement has begun.
What the rule requires
A new director must verify their identity before acting in the role. This has applied to new appointments since 18 November 2025. Directors already in office got a 12-month transition period. However, the deadline is tied to the company's next confirmation statement, so each director may have a different date. Verification is free online through Companies House. Also, an authorised corporate service provider can do it.
Three directors, two companies
- Jill White, White (Reading Properties) Limited. She kept acting as a director without verification. She took part in board decisions and signed the accounts. But she verified only in early September 2026, about nine months late. Her fine was £166, plus £85 costs and a £66 victim surcharge. In addition, she was convicted with another director for filing the confirmation statement late.
- Marc Dillon, the same company. He had verified his own identity. But he did not take reasonable steps to stop White from acting while unverified. Therefore, he was convicted too. His fine was £307, plus £85 costs and a £123 victim surcharge.
- Modinat Banjo, J Isogony Apparel Limited. She signed and delivered the accounts before she verified. She finished verification around 28 May 2026. She also filed the confirmation statement late. Her fine was £80, plus £85 costs and a £32 victim surcharge.
The Insolvency Service says both companies had several chances to comply. However, there is no way to opt out of verification. In addition, Companies House reported 23 director disqualifications in the first half of 2026, 70 years in total.
The main lesson: your own status is not enough
Dillon's case deserves a second read from every board. A verified director can still be convicted. This happens if they know a colleague is unverified and do nothing. For example, the colleague may keep signing documents or voting at board meetings. Under the Companies Act 2006, the acts of an unverified director stay valid. However, criminal liability remains. It applies to the director, the company and any officer in default.
What to do now
- First, verify every director, including those who live abroad.
- Then check the deadline for each one.
- In addition, keep an internal register. List directors and persons with significant control, their deadlines and their verification status. Check that each code is linked to the correct role.
- So before a board decision or signing accounts, confirm that everyone involved may act.
- If a co-director is unverified, raise it formally and record what you did. If their activity cannot be paused, get legal advice.
- Finally, remember what verification does not do. It confirms identity only. But it does not prove beneficial ownership, and it does not replace your own AML checks.
If you have a UK company, the FBS team can help you check directors' statuses and deadlines.