Companies House and the Director Verification Regulations

A Possible Legal Challenge to Digital-Only Enforcement?

CONSCIENTIOUS CURRENCY

On 4 November 2025, I contacted Companies House to seek urgent clarification regarding the identity verification routes for company directors under the new regulations coming into force on 18 November 2025 in the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025.

Current guidance on the GOV.UK website states that director identity verification can only be completed via two routes: GOV.UK One Login or through an Authorised Corporate Service Provider (ACSP). Both routes raise serious concerns, particularly considering the UK’s broader push toward mandatory digital identity infrastructure. The concern is that director verification is a form of mandatory digital identity by stealth, with One Login positioned as the default mechanism for compliance – see below screenshot taken 04.11.2025 from this website https://www.gov.uk/guidance/verifying-your-identity-for-companies-house

One Login is the UK’s centralised digital ID platform, and its use raises significant privacy and security issues. It is designed for interoperability across government and private services, meaning that data held within it can eventually be linked to bank accounts and other personal systems. This creates a risk that individuals could be locked out of accessing essential public or private services if they fail to meet certain societal criteria. For these above reasons alone, I argue that One Login should be avoided at all costs. Moreover, One Login lost its safety certification in May 2025, raising huge concerns about users exposure to data breaches, hacking, and the potential sale of sensitive personal information on the dark web. You can find out more on this in a past article I wrote and accompanying video I made here:

Turning to the specific issue of director verification, I examined Regulation 6 of the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025.

• Regulation 6(1) states that: “An individual may apply to the registrar for verification of their identity if the individual is not an individual whose identity is verified…”
• Regulation 6(3)(a) further provides that: “An application under paragraph (1) or (2) must be in writing.”

This language therefore appears to permit direct written applications to the registrar, including non-digital formats — a route that is not mentioned on the GOV UK guidance page.

I also reviewed the Registrar’s Identity Verification Rules 2025, which came into force on 25 February 2025. These rules define acceptable forms of ID and evidence for verification, but they do not operationalise the written application route permitted by Regulation 6.

In view of the apparent contradiction between statutory law and government guidance, I contacted Companies House to request clarification. For complete transparency, and in case it may be of interest to you, here is the correspondence I have sent and received to/from Companies House, on this matter:

Email from me to Companies House:

Subject: Urgent query regarding Company director verification routes
Date: 04/11/25 13:11
From: Clare Wills Harrison

Dear Companies House Team,

I am writing to seek urgent clarification regarding the identity verification process for company directors under the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025 (“the Regulations”).

Specifically, Part 2, Chapter 3, Regulation 6 (3) (a) of the Regulations state that “(1) An individual may apply to the registrar for verification of their identity if the individual is not an individual whose identity is verified and “An application under paragraph (1) or (2) must be in writing”. This regulation therefore appears to permit direct written applications for identity verification to the registrar, including in non-digital formats.

However, GOV UK guidance at today’s date currently states: “You can only verify your identity for Companies House using the following options (being OneLogin or the ACSP route). Do not post or email your identity documents to us.”

I have also reviewed the Registrar’s Identity Verification Rules 2025, which came into force on 25 February 2025. These rules define acceptable forms of ID and evidence for verification routes, but do not operationalise any written application route permitted by Regulation 6 of the Regulations.

In view of the above I would be grateful if you would clarify:

1. Whether Companies House accepts written applications for identity verification as permitted under Regulation 6, directly from company directors, and if so how this is facilitated?

2. If not, what is the legal basis for excluding this route, given the wording of the Regulations?

3. Whether the Registrar’s Rules were intended to exclude or support written applications?

4. Whether any internal policy or legal advice supports the digital-only enforcement?

Given the short timeframe until implementation of director verification requirements on 18th November 2025, I appreciate your guidance on this matter and look forward to your earliest response by return email to this address.

If my email needs to be forwarded to your legal team for a response, I of course give my permission for it to be so forwarded, but would be grateful if you would in that case supply the email address for the legal team so I can correspond direct.

Yours sincerely,

Clare Wills Harrison

Reply from Companies House:

From:enquiries <[email protected]>

5 November 2025 at 15:49

To: “Redacted”

Dear Customer,

Thank you for your email.

Ways to verify your identity

Online

You can verify online if you have the identity documents or information required. This route uses GOV.UK One Login to verify your identity and is free of charge https://www.gov.uk/using-your-gov-uk-one-login/proving-your-identity

You’ll need one of the following types of photo ID:
Biometric passport (from any country)
UK photo driving licence (full or provisional)
UK biometric residence permit (BRP)
UK biometric residence card (BRC)
UK Frontier Worker permit (FWP)

GOV.UK One Login will ask you some simple questions to find the best way for you to verify your identity online. Depending on your answers, you’ll then be guided to verify using a GOV.UK mobile phone app or in your web browser.

If you do not have any of these types of ID but live in the UK, you may be able to verify with bank or building society details instead. You’ll need to use the ‘Verify your identity for Companies House’ service to find out if you can verify this way.

In person at a Post Office

If you cannot verify online and you live in the UK, you may be able to verify your identity in person at a Post Office. You’ll need to use the ’Verify your identity for Companies House’ service first to find out if you can verify this way. This route uses GOV.UK One Login to verify your identity and is free of charge. Please use the following links for more information

https://www.gov.uk/guidance/verifying-your-identity-for-companies-house

Using an Authorised Corporate Service Provider (ACSP)

You can ask an Authorised Corporate Service Provider (ACSP) to verify your identity on your behalf. For example, an accountant or solicitor. This is also known as a Companies House authorised agent.
You can do this from any country, but your agent must register with Companies House in order to become authorised. They must be registered with a UK Anti-Money Laundering (AML) supervisory body.
There is not a public register of ACSPs available. Individuals or entities wishing to use an ACSP for ID verification will need to make their own enquiries.

Please see the following link below for further information on ACSPs:

https://www.gov.uk/g​uidance/verifying-yo​ur-identity-for-comp​anies-house
When an agent has agreed to verify your identity, you will need to provide documents from an approved list as evidence of your identity. They may charge a fee for their services.

If you require any further assistance, please do not hesitate to contact us.

To get in touch you can email us at [email protected] or call our Contact Centre on +44(0)303 1234 500

Alternatively please visit our website at https://www.gov.uk/government/organisations/companies-house

Yours faithfully,

[Name redacted]

Companies House Contact Centre
[email protected]

My view is that this response from Companies House fails to address the statutory right to submit a written application for verification. Instead, it reiterates GOV UK guidance that identity verification “can only” be completed via One Login or an ACSP — a position that appears to contradict the Regulations and which may as a consequence be ultra vires.

I have therefore sent a follow up email today. In it I raised concerns about:

• The legal exclusion of a route seemingly explicitly permitted by law
• The disproportionate impact on digitally excluded individuals
• The financial burden imposed by ACSPs
• The lack of clarity in the Registrar’s Rules

My follow up email of today:

From: Clare Wills Harrison at 12:49pm)

to [email protected]

Dear [Name redacted]

Thank you for your email. However, it is disappointing that you have not addressed any of the issues raised in my query of 4 November 2025 regarding the identity verification process under the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025 (“the Regulations”).

Notably, your reply does not confirm whether written applications — which appear expressly permitted under Regulation 6(3)(a) — are accepted, nor does it provide a clear legal basis for the exclusion of non-digital formats.

As previously stated, Regulation 6(1) permits an individual to apply to the registrar for verification of their identity. Regulation 6(3)(a) further specifies that such an application must be in writing. This provision is unambiguous and appears to permit direct written applications to the registrar, including non-digital formats.

The Registrar’s Identity Verification Rules 2025 do not operationalise this route, nor do they explicitly exclude it. The GOV UK guidance, which states that identity verification “can only” be completed via One Login or an ACSP, therefore appears to contradict the Regulations and may be ultra vires.

Furthermore, the requirement to use an ACSP — which involves payment of fees — imposes a financial barrier that disproportionately affects individuals who are digitally excluded or unable to verify online. This compounds exclusion and raises concerns of procedural unfairness and indirect discrimination, particularly where a statutory route for written application exists but is not operationalised.

In light of this, I respectfully request a clear and legally reasoned explanation for the exclusion of written applications. If Companies House intends to refuse such applications, I reserve the right to initiate judicial review proceedings on the following grounds:

• Illegality – Exceeding the authority granted by Regulation 6
• Irrationality – Failing to provide a route explicitly permitted by law
• Procedural unfairness and discrimination – Disproportionate impact on digitally excluded individuals and those unable to afford ACSP fees

I would welcome a substantive and legally reasoned response within 7 days. If no satisfactory clarification is provided, I will consider issuing a formal pre-action protocol letter under the Civil Procedure Rules.

For the avoidance of doubt, please answer the following questions in your reply:

1. Does Companies House accept written applications for identity verification as permitted under Regulation 6, directly from company directors? If so, how is this facilitated?
2. If not, what is the legal basis for excluding this route, given the wording of the Regulations?
3. Were the Registrar’s Rules intended to exclude or support written applications?
4. Is there any internal policy or legal advice that supports the digital-only enforcement model?

I await hearing from you.

Your sincerely

Clare Wills

Summary:

I will keep you all posted as to any further reply I receive from Companies House, but in the meantime please let me know if you have any thoughts on the regulations and what they say as I could do with some help with looking at this, particularly if you are a company director yourself.

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This article (Companies House and the Director Verification Regulations) was created and published by Clare Wills Harrison and is republished here under “Fair Use”

Featured image: ft.com