What is Companies House identity verification?
A requirement introduced by the Economic Crime and Corporate Transparency Act 2023, under which every name on the companies register must correspond to a verified individual. Verification became available voluntarily on 8 April 2025 and mandatory on 18 November 2025, with a twelve-month transition period for those already in post, making 18 November 2026 the backstop.
The scale is considerable, with Companies House estimating that around six to seven million people must comply by that date. The change also alters what Companies House is, since the register has moved from a passive repository to an active gatekeeper with powers to query, reject and remove information which it did not previously hold.
For a pharmacy owner this sits alongside the other dates examined in our horizon piece, and shares their characteristic, in that the work is small and the consequence of missing it is not.
Who has to verify?
Three categories currently, and the second is the one pharmacy structures complicate.
Directors of UK-registered companies, including executive and non-executive directors, and including directors of overseas companies with UK establishments.
People with significant control, being broadly those holding 25 per cent or more of the shares or voting rights, or otherwise exercising significant influence or control. A shareholding pharmacist who is not a director is captured here, which is regularly overlooked.
Members of limited liability partnerships, whose deadlines work in the same way as those for company directors, though this does not apply to corporate LLP members.
An individual who is both a director and a PSC of the same company verifies once, obtaining a single personal code, whilst holding obligations in both capacities with different deadlines attached.
When is your actual deadline?
| Who | Deadline |
|---|---|
| Existing director at 18 November 2025 | The next confirmation statement filed on or after that date |
| Existing PSC who is also a director | Fourteen days from the company's confirmation statement date |
| Existing PSC who is not a director | Fourteen days from the first day of their birth month |
| Newly appointed director | Before the appointment can be registered, including at incorporation |
| New PSC registered after 18 November 2025 | Fourteen days from registration, with a letter from Companies House marking the start |
| Absolute backstop for existing officeholders | 18 November 2026 |
The birth month rule for non-director PSCs deserves a worked example because it is easily misread. A PSC whose recorded date of birth falls in January has a fourteen-day window beginning on 1 January, rather than fourteen days from their actual birthday. An owner whose spouse or family member holds shares without being a director should establish that date rather than assume November.
The confirmation statement trap
The backstop of November 2026 is not the operative date for most companies, and treating it as such is the error this section exists to prevent. From 18 November 2025 the personal codes of all directors must be included when a confirmation statement is filed, and if any director has not verified, the company cannot file at all, regardless of whether that individual's own deadline has technically passed. A pharmacy company with three directors, two of whom verified promptly, cannot file its statement because of the third. The consequence escalates from there, since a company which cannot file its confirmation statement is at risk of being struck off the register, and a struck-off company owning a registered pharmacy creates a problem which extends well beyond Companies House. The practical instruction follows directly. Establish the company's confirmation statement date, work backwards, and ensure every director has verified in advance rather than discovering the gap on the filing deadline. Where an accountant files on the company's behalf, they cannot file either, and the first a busy owner may hear of it is a message saying the submission was not possible.
How do you verify, and what is a personal code?
Verification is completed either directly with Companies House or through an Authorised Corporate Service Provider, being a supervised firm such as an accountant or solicitor able to conduct the check. Once complete, the individual receives a Companies House personal code, which is the identifier then supplied for each directorship and each PSC registration.
One feature saves considerable effort for anyone holding several pharmacy companies. The code attaches to the person rather than to the company, so an individual verifies once and provides the same code across every directorship, though the filing obligations arise separately for each company and each will need the code supplied at its own confirmation statement.
One preparatory step prevents most failures. The personal details held on the Companies House register, particularly the recorded date of birth, must match the identity documents being used, and where they do not the verification cannot complete. Correcting a register error takes time which a filing deadline may not allow, so checking the register entry before starting the process is worth the five minutes it takes.
How do pharmacy ownership structures complicate this?
Pharmacy ownership is frequently arranged through more than one entity, and each arrangement produces its own obligations.
Holding company structures. Where an operating company is owned by a holding company, the individuals behind the holding company may be PSCs of it, whilst the holding company itself appears as a corporate PSC of the operating company. Identity verification requirements for officers of corporate PSCs, corporate directors and corporate LLP members are being introduced at a later date, so the current position may be incomplete rather than settled for such structures.
Multiple pharmacy companies. An owner holding several companies faces several confirmation statement dates, each requiring every director's code, which means the practical task is a schedule rather than a single action.
Family and passive shareholders. A spouse, sibling or parent holding 25 per cent or more without any operational involvement is a PSC with a birth-month deadline, and is precisely the person least likely to be watching for correspondence from Companies House.
Recent acquisitions. A pharmacy bought in the past year may have brought with it directorships, resignations and share transfers not yet fully reflected on the register, and the verification process is where those discrepancies surface.
Why does this matter beyond Companies House?
Because a pharmacy company is not an ordinary company, and a corporate filing failure has consequences the general commentary does not address.
A body corporate owning a registered pharmacy operates under superintendent pharmacist arrangements, with the superintendent's position and the company's ownership both matters the GPhC records and expects to be accurate. Where a company is struck off, the ownership of the registered pharmacy premises becomes a question requiring resolution with the regulator as well as with Companies House, and restoration is neither quick nor certain.
Two adjacent consequences follow. Ownership and control information is examined during payments underwriting and banking diligence, as this library's payments material sets out, and a register entry which is out of date or a company in poor filing standing is precisely the sort of finding which stalls an application. And any transaction, whether a sale, a refinancing or a new supplier arrangement, will involve someone reading the register, at which point unverified officers and overdue filings become the buyer's questions rather than the owner's.
None of that is dramatic. It is simply that a pharmacy carries more downstream dependencies upon its corporate record than most small businesses, which raises the return on keeping it tidy.
What happens if you do not verify?
Failing to comply with the identity verification requirements is an offence, and Companies House has published its approach to non-compliance and the enforcement action it intends to take. Reported consequences include financial penalties, criminal sanction and disqualification, and it is worth noting that acting as a director whilst unverified is itself part of what the regime addresses.
In practice the earlier and more likely consequence is procedural. The company cannot file its confirmation statement, the filing becomes overdue, and the register records a company in default, with strike-off proceedings the eventual result if the position is not corrected. For a pharmacy owner that is the outcome to plan around, because it arrives first and is entirely avoidable.
What is coming next?
The regime is being phased rather than completed. Verification requirements for individuals filing documents on behalf of companies were reported as extending from spring 2026, which affects accountants, company secretaries and anyone submitting filings for a pharmacy business.
Requirements for limited partnerships, corporate directors, corporate LLP members and officers of corporate PSCs are to be introduced at a later date, which is directly relevant to the holding company structures described above. An owner whose arrangements involve corporate entities should treat the current position as an instalment rather than a conclusion, and should expect further steps to be required.
What to do this month
Six actions, none taking long, and all cheaper now than in November.
Establish the confirmation statement date for every company you hold, since that is the real deadline rather than November. List every director and every PSC across those companies, including passive family shareholders. Check that the details on the register match the identity documents each person will use, particularly dates of birth. Verify, obtain personal codes and record them somewhere the person filing can reach. Identify any non-director PSCs and calculate their birth-month deadlines, which may already have passed. And confirm with your accountant who is filing what, and that they hold what they need, rather than assuming the matter is in hand.
Key takeaways
- Identity verification became mandatory on 18 November 2025 under the Economic Crime and Corporate Transparency Act 2023, with a twelve-month transition ending 18 November 2026 and six to seven million people required to comply.
- Directors, people with significant control holding 25 per cent or more, and LLP members must all verify, including shareholders with no operational role.
- The real deadline for most companies is the confirmation statement rather than November, and the deadline for a non-director PSC runs from the first day of their birth month rather than their birthday.
- A confirmation statement cannot be filed at all unless every director has verified, so one unverified director blocks the company and eventually risks strike-off.
- A personal code attaches to the individual rather than the company, so one verification covers every directorship, though each company must be filed separately.
- Pharmacy structures complicate matters through holding companies, multiple entities, passive family shareholders and recent acquisitions with untidy registers.
- A struck-off company owning a registered pharmacy is a regulatory problem as well as a filing one, and the register is read during payments underwriting, banking diligence and any transaction.
FAQs
One code, every company.
Corporate deadlines fail for the same reason clinical ones do, which is that nobody owns the date. The compliance calendar this library keeps returning to should hold confirmation statement dates alongside GPhC renewals, DSPT submission and service review intervals, in one place somebody actually looks at.
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