Most property developers and investors we work with run more than one company. A separate SPV for each site, an investment holding company on top, maybe a management company for a block, all with the same one or two people down as director and person with significant control (PSC) on every one. Companies House's new identity verification requirement lands squarely on that structure, and because it is phased in company by company rather than on a single fixed date, it is easy for a director to miss their own deadline while assuming someone else is handling it.
What identity verification actually requires
Under the Economic Crime and Corporate Transparency Act 2023, every individual acting as a company director or registered as a PSC must verify their identity with Companies House. The same requirement applies to anyone who files on a company's behalf as an authorised corporate service provider (ACSP), a category that covers most accountants and formation agents who submit filings for clients. There are two routes: verifying directly through GOV.UK One Login, using photo ID and a selfie match, or verifying indirectly through an ACSP who checks the individual's identity and confirms it to Companies House on their behalf.
The dates that actually matter
Voluntary identity verification opened on 8 April 2025, letting directors get ahead of the requirement before it applied to them. It became compulsory for new director appointments and new company incorporations from 18 November 2025; nobody has been able to become a first-time director or incorporate a new company since that date without verifying identity as part of the process. For directors and PSCs of companies that already existed before that date, the requirement is phased in through a 12-month transition tied to each company's own confirmation statement, so the actual deadline is the date of the first confirmation statement due after the compulsion date, not one single day for the whole register. Two companies incorporated a month apart can end up with verification deadlines many months apart purely because their confirmation statement dates differ.
Why this catches multi-SPV structures in a specific way
The requirement is attached to the individual, not the company. Verify once, through One Login or an ACSP, and that verification covers every company the person is already recorded against as a director or PSC, whether that is one company or fifteen. The practical risk for someone running a portfolio of SPVs, the kind of structure our guide to when an SPV makes sense covers, is not needing to repeat the process for each entity. It is the opposite: because the deadline is set by whichever company's confirmation statement falls due first, a director can verify comfortably ahead of the deadline on their oldest company and not realise a newer SPV in the same portfolio, with an earlier confirmation statement date, actually needed it sooner. The same point applies to a family investment company where several family members are named PSCs; each of them needs to verify individually, on their own timetable, not as a single household action.
What happens if it is missed
Failing to verify when required is a criminal offence for the individual concerned. Separately, and more likely to be noticed in practice, Companies House can refuse to register a filing, including the confirmation statement itself, for a company whose directors or PSCs have not verified. A company that cannot get its confirmation statement accepted is itself committing an offence, and persistent failure to file is one of the routes that leads to a company being struck off the register, with the knock-on consequences for bank accounts, contracts and any property held in that company's name that a strike-off brings. None of this requires HMRC or a lender to notice first; it sits entirely within Companies House's own filing gateway.
Using an accountant as the verification route
A director does not have to use GOV.UK One Login personally. An accountant or formation agent registered as an authorised corporate service provider can verify a client's identity and confirm it to Companies House instead, which is often the more practical route for a director already working with an agent on filings and Corporation Tax. The one thing worth checking before relying on this route is that the firm being used is actually on the ACSP register; not every accountant has registered to offer verification as a service, and confirming that in advance avoids a last-minute scramble as a confirmation statement deadline approaches.
What to do now, not at the deadline
The sensible approach is to verify identity for every director and PSC across a portfolio in one sitting, well ahead of any individual company's confirmation statement date, rather than waiting to see which company's deadline arrives first. It takes minutes through GOV.UK One Login for someone with a valid passport or UK driving licence, and once done it does not need repeating as new companies are added to the structure later. For a portfolio built the way most property developers build one, adding an SPV per site over time, that one piece of admin done early removes the risk of a confirmation statement bouncing on a technicality that has nothing to do with the company's actual filings or accounts.
Common questions
Who has to verify their identity at Companies House?
Every individual who is a director or a person with significant control (PSC) of a UK company has to verify their identity with Companies House, along with anyone who files on a company's behalf as an authorised agent. It applies whether the company is trading or a dormant property-holding SPV, and regardless of how many other companies the same individual is already a director of.
When do existing directors need to verify their identity by?
Identity verification became compulsory for new director appointments and new company incorporations from 18 November 2025. Directors and PSCs of companies already on the register must verify within a 12-month transition period tied to their company's confirmation statement, meaning the deadline falls on the date of the first confirmation statement due after that date rather than on a single fixed day for everyone.
Do I need to verify separately for each property company I am a director of?
No. Verification is tied to the individual, not the company. Once verified through GOV.UK One Login or an authorised corporate service provider, that verification covers every company the person is a director or PSC of, including a portfolio of several property SPVs run by the same individual.
What happens if a director does not verify their identity?
Failing to verify when required is a criminal offence for the individual. Companies House can also refuse to register filings, including the confirmation statement, for a company whose directors or PSCs have not verified, and a company that cannot file its confirmation statement is itself committing an offence that can eventually lead to it being struck off the register.
Kieran Holsgrove is a Director and Co-Founder of Grafene Accounting, the property tax specialist firm based in Liverpool. He advises property developers, investors and landlords across Merseyside, Greater Manchester, Lancashire and Cheshire on tax structuring, developer VAT, SDLT and the long-view decisions that compound over the life of a portfolio.
This article is general information, not personal tax advice, and tax rules change. Your own position depends on facts we cannot see from here — please take advice before acting on anything above.