The quiet milestone that many formation agents had been watching arrived last week without fanfare. Since 5 March 2026, any company filing a confirmation statement at Companies House must include directors and persons with significant control who have completed identity verification. The transition period that began on 18 November 2025 has now entered its operational phase — and for Authorised Corporate Service Providers handling portfolios of client companies, the pressure is real.

Under the Economic Crime and Corporate Transparency Act 2023, an estimated six to seven million individuals across the UK must verify their identity with Companies House by 17 November 2026. Existing directors must complete verification before their company files its next confirmation statement after 5 March. For PSCs who are not directors, the 14-day verification window is triggered from the first day of their month of birth as shown on the register. March-born PSCs, for instance, had their window open on 1 March.

This is not a theoretical compliance exercise. It is an offence to act as a director without being verified once the duty attaches, and Companies House can impose civil penalties of up to £10,000 for non-compliance. For formation agents and corporate service providers, the risk extends beyond individual penalties. If your ACSP status is revoked for verification failures, you lose the ability to file on behalf of clients entirely — a potentially business-ending consequence.

The verification system offers two routes. Individuals can verify directly through GOV.UK One Login, a free digital process that typically takes 10 to 20 minutes using a passport or photocard driving licence. Alternatively, they can verify through a registered ACSP, which can use ID document validation technology to authenticate biometric and machine-readable documents. ACSPs typically charge around £35 plus VAT for this service.

It is this second route where AI-powered verification technology is becoming essential infrastructure. ACSPs processing hundreds or thousands of verifications cannot rely on manual document checks at scale. Identity verification platforms using machine learning for document authentication, facial matching, and liveness detection are now standard tools in the formation agent's technology stack. These systems can validate cryptographic features on identity documents, cross-reference against watchlists, and flag anomalies in seconds rather than minutes.

The commercial opportunity is significant. With millions of individuals requiring verification and many lacking the technical confidence to navigate GOV.UK One Login independently, ACSPs offering a managed verification service are seeing strong demand. But the compliance burden is equally significant. ACSPs must verify to the statutory standard, retain records of every check, and file a verification statement confirming the outcome. Errors in this process carry direct regulatory consequences.

The broader digital transformation at Companies House continues to accelerate alongside the IDV rollout. From 1 February 2026, filing fees were updated — incorporation now costs £100 digitally, confirmation statements £50, and voluntary strike-offs £13. The presenter requirements that would require all filers to be registered ACSPs have been postponed from spring to no earlier than November 2026, giving the sector additional breathing room on that front. But the IDV transition itself is firmly on track.

For ACSPs and formation agents, the practical steps are clear. First, audit your client portfolio to identify every director and PSC who has not yet verified. Second, establish a systematic outreach programme — do not wait for clients to contact you. Third, ensure your verification technology meets the statutory standard and that your record-keeping is audit-ready. Fourth, consider the commercial model: whether to absorb verification as part of existing service packages or offer it as a standalone fee-based service.

The key dates from here are straightforward. PSCs who are not directors will have their verification windows triggered month by month based on their registered birth month. All existing directors must be verified by 17 November 2026. And from no earlier than November 2026, the presenter requirements will mean that only registered ACSPs can file at Companies House on behalf of clients.

The formation sector has navigated regulatory change before — from the PSC register introduction to AML supervision requirements. But the IDV transition is different in scale and operational intensity. Six to seven million verifications in twelve months is an infrastructure challenge as much as a compliance one. The firms that have invested in AI-powered verification technology and systematic client management will process this transition smoothly. Those still relying on manual processes may find the next eight months extremely difficult.

17 November 2026. That is the date every formation agent should have circled. The clock is running.