Ten Days, Six Million Directors: Companies House Identity Verification Closes 18 November

18 November 2026. That is the date. Write it on a Post-it and stick it somewhere the partners will actually see it, which probably means the coffee machine.

The twelve-month transition period for mandatory director and PSC identity verification under the Economic Crime and Corporate Transparency Act 2023 closes that day. The requirement itself has been law since 18 November 2025. What changes on the 18th is not the rule but Companies House's enforcement posture, and the register has been explicit that it intends to act.

What the Register Has Actually Said

Companies House management information published on 30 July 2026 showed that by the end of June, only 55% of directors, 50% of LLP members and 42% of PSCs had linked a verified identity to the register. That means roughly four to five million individuals still need to act, against a window that closes in ten days. Companies House itself estimates the total population requiring verification at six to seven million. The maths is uncomfortable.

From 18 November 2026, Companies House has confirmed it will reject filings connected to unverified individuals. This is not soft enforcement. The rejection mechanism is automatic. Acting as a director without having completed identity verification is an offence under section 167M of the Companies Act 2006, with consequences running to financial penalties, annotation on the public record, and in serious cases prosecution.

One accounting practice's advisory note captures the operational reality plainly: "November will be a stampede - every company with a December confirmation statement will discover the requirement at once, and identity-document edge cases (expired passports, name changes, no photo ID) take weeks to resolve, not minutes."

Who Is Caught, and By When

New directors appointed after 18 November 2025 have faced the requirement since day one: they cannot act until verification is complete. Existing directors and PSCs had until their company's next confirmation statement date, or 18 November 2026, whichever came first. A significant portion of the market has therefore been in breach since well before the nominal deadline.

One nuance practices should not overlook: presenter verification, covering those who file documents on a company's behalf without holding an office, has been pushed back to no earlier than November 2027. That is one part of the ECCTA timetable where the pressure valve has been released. Director and PSC verification has not moved a single day, despite revisions to other elements of the transition plan in January and August 2026.

What This Means for Your Monday Morning

The workflow is not complicated, but the volume is. Work through it in this order.

Step one: audit the client list. Cross-reference your company secretarial records against Companies House to identify every director and PSC who has not yet provided a verified identity code. The register shows verification status on the company record. Any client due a confirmation statement in December, January or February is now critical priority.

Step two: triage by filing date. Clients whose confirmation statement falls in the next eight weeks face the most immediate filing risk. An unverified director will block submission. A blocked confirmation statement triggers its own late-filing penalties, compounding the original ECCTA offence.

Step three: chase with specific instructions. The two routes to verification are the GOV.UK One Login portal (direct, suitable for most UK passport or driving licence holders) and via an Authorised Corporate Service Provider. Edge cases, including overseas passport holders, individuals with name changes, and those without photographic ID, need an ACSP route. Flag these explicitly; do not let them discover the problem at the portal on 17 November.

Step four: document the chase. Under the ECCTA framework, the firm's own regulatory exposure depends partly on whether it took reasonable steps to bring clients into compliance. Keep a file note for every client contact.

Step five: update the engagement letter template. Confirmation statements filed after 18 November must include verified identity codes. If your standard letters do not yet make this a client obligation, fix them this week.

The Shareholder Register Wrinkle

Since 26 January 2026, the central-register election for a company's register of members was withdrawn. Any company that had elected to keep its shareholder register only at Companies House must now maintain a proper physical (or cloud-hosted) register at its registered office or single alternative inspection location. This is a separate obligation that has been quietly catching out companies whose secretarial records have not been reviewed since before January. If you are doing a full client audit this week, add it to the checklist.

A Second Clock: The SRA and AI Supervision

The Companies House deadline is the acute pressure. There is, separately, a compliance matter worth flagging to any client operating a law firm or legal services business. The SRA's warning notice on the misuse of AI, published on 17 August 2026, is now the regulator's operative word on the subject. Its position is unambiguous: AI has no separate legal personality, and regulated individuals remain accountable for all work and advice delivered to clients, whether or not AI was used in its preparation.

The SRA has also reported 42 cases of potential AI misuse logged between July 2025 and July 2026, covering hallucinated citations and confidentiality breaches caused by inputting client documents into open-source tools. Its effective supervision guidance, updated in June 2026, now includes an AI section requiring that an authorised individual retains ultimate responsibility for AI-assisted legal services. Firms that have not yet produced a written AI policy covering approved tools, verification obligations and confidentiality controls are running a compliance gap. The COLP is the named accountability point.

This is the sort of thing that looks fine until it doesn't, which in the Law Society's experience of regulatory cycles tends to happen precisely when everyone is distracted by something else. Like, to pick a topical example, six million identity verification notices.

The Class 45 Signal

Brand activity in the legal and professional services space supports the picture of a market under administrative pressure. AIBD analysis of IPO Trade Mark Dashboard data shows just 826 Class 45 trademark filings in the UK in Q4 2026, a fall of 52.5% against the prior period. Class 45 covers legal services, security services and personal or social services. When that filing rate collapses, it generally signals one of two things: either the legal services market is contracting, or firms are too busy managing operational compliance to think about brand. In the current environment, the second explanation is doing considerable work.

The Next Deadline on the Horizon

2 December 2026. For UK businesses with EU operations, that is the date by which providers of AI systems already on the market must implement watermarking and transparency solutions for AI-generated content, under the EU AI Act's Article 50(2). This obligation was deferred from 2 August 2026 by the Digital Omnibus agreement of May 2026. It did not go away. Any client running AI-generated audio, image, video or text products touching EU users needs to have that in the diary now, not on 1 December.

But first: eighteen days from today, six million people need to have told Companies House who they are. Clear the decks.