Companies House announced a crackdown on bogus company directors on 18 November 2025. Its own guidance says that date was never a deadline, and the real one is nine weeks away with no published number behind it.
Estimated reading time: 6 minutes
In short. Companies House's 18 November 2025 press release announced enforcement action against "bogus directors" the same week the requirement it was enforcing began. Its own guidance, published alongside it, says that date "is not a deadline" but the start of a 12-month transition period that actually ends 18 November 2026, nine weeks from today. The only participation figure Companies House has published, 1.5 million people who verified voluntarily since April 2025, counts a self-selected group that predates the legal requirement, not the millions of existing directors and PSCs whose individual deadlines fall due across that transition year. Companies House publishes compliance rates for confirmation statements and annual accounts every year. It has never published one for identity verification. Three documented mistakes: four stars.
On 18 November 2025, Companies House told the public it had "served notice on bogus directors" as mandatory identity verification came into force. The same day, in a separate guidance page, it told company directors something quieter: the date on the press release was not, in fact, the date most of them needed to do anything about.
The claims, tested
| The document's own words | What the record actually shows | Verdict |
|---|---|---|
| The press release announcing the policy's start: "Notice served on bogus directors as Companies House changes come into force," 18 November 2025 [1] | Companies House's own guidance, published the same week: "From 18 November 2025, identity verification becomes a legal requirement. This date is not a deadline. It marks the start of a 12-month transition period, giving your company time to make sure all directors and people with significant control (PSCs) have verified their identity by their due dates." [2] | An enforcement-themed announcement pinned to a date that obliges an existing director to do nothing until their company's next confirmation statement, which can fall up to a year later |
| The same press release's headline evidence for compliance: "More than 1.5 million individuals have already verified their identity since Companies House launched its identity verification service on a voluntary basis in April" [1] | That figure covers people who verified before the requirement was mandatory, largely new incorporations and users of Authorised Corporate Service Providers. The guidance for existing directors states they "will need to provide your Companies House personal code as part of your company's next confirmation statement" [3], and no published figure states what proportion of the existing-director population has done so | The one participation number in circulation measures a different, self-selected cohort to the mandatory backlog whose deadline is now nine weeks away |
| Companies House's own description of what it routinely publishes: "Management information provides annual figures for private limited companies, PLCs and LLPs, including: compliance rates for confirmation statements and annual accounts, late filing penalties imposed" [4] | The identity verification collection page lists guidance and service pages only; no statistical release on verification compliance rates appears among Companies House's published statistics [5] | A regulator that already measures and publishes compliance for every other filing duty has not built or published the equivalent measure for the duty ending in nine weeks |
| Companies House's published enforcement policy: non-compliant users get "a default letter" explaining the offence, after which the regulator "may pursue enforcement action without further notice," through "prosecution through court," "referral to The Insolvency Service" or "financial penalties" [6] | The same document allows a "representation" from a non-compliant director, after which Companies House "may pause pursuit of non-compliance for a temporary period," with no defined length stated anywhere in the published policy | An enforcement ladder with a discretionary, undefined pause built into its first rung, published without a companion figure for how often it has been used |
The mistakes, counted
A crackdown announcement pinned to the start of a grace period, not its end (1). The press release naming 18 November 2025 as the day Companies House "served notice on bogus directors" is accurate about the date the legal requirement began, and inaccurate by implication about what it obliged anyone to do that day [1]. The regulator's own guidance, published the same week, states plainly that 18 November 2025 "is not a deadline" and instead opens a 12-month transition period, with each existing director's or PSC's actual due date tied to their company's next confirmation statement, a date that can fall anywhere across the following year [2] [3]. A reader of the press release alone would not learn that the transition window Companies House itself designed runs until 18 November 2026, sixty-four days from this piece's publication.
A headline compliance figure that answers a different question (2). The only concrete participation number Companies House has put in public, 1.5 million people verified "since Companies House launched its identity verification service on a voluntary basis in April," was announced in the same release framed as evidence the crackdown was working [1]. That figure describes voluntary sign-ups predating the legal requirement, a population weighted toward new company formations and agents filing on behalf of clients, not the stock of directors and PSCs already on the register who are obliged to verify by their individual confirmation-statement dates during the transition year [3]. Companies House has not published, alongside or since, a figure for what share of that existing population has complied.
A statistics gap on the one duty that most needs one (3). Companies House describes its own statistical practice as covering, every year, "compliance rates for confirmation statements and annual accounts, late filing penalties imposed and appeals received" [4]. The collection page gathering every identity verification guidance and service document contains no equivalent statistical release [5]. The regulator's enforcement policy, meanwhile, describes a "representation" process that can pause action against a non-compliant director "for a temporary period" with no length specified anywhere in the published document, and offers no public count of default letters sent, penalties issued or Insolvency Service referrals made in the ten months since the requirement began [6]. Nine weeks before the transition period it designed comes to an end, Companies House has not published the number that would let anyone outside the organisation judge whether it worked.
Credit where due
The underlying design is not the problem here. Tying each existing director's deadline to their company's own confirmation statement, rather than a single fixed date for millions of people at once, spreads a large administrative task sensibly across a year rather than creating one unmanageable cliff edge. The enforcement policy is genuinely published in detail, naming its three routes and the factors weighed before using them, rather than left vague or withheld [6]. And the requirement itself, created by section 64 of the Economic Crime and Corporate Transparency Act 2023 and the sections around it, closes a real gap: a company register that for two centuries took an officer's stated name on trust [7].
Verdict
Four stars, from three documented mistakes. The identity verification duty is real, sensibly staggered, and backed by a published enforcement policy with named routes rather than empty threats. What is missing is the figure that would let anyone check whether it is working: not a fixed compliance rate at one point in time, but the kind of annual measure Companies House already builds for confirmation statements and accounts, applied to the duty that is about to reach its own deadline. A press release calling 18 November 2025 the day enforcement began was accurate. Calling it the day most directors needed to act was not, and the one number offered as proof of progress was never measuring the group whose deadline, sixty-four days from now, still has no public score attached to it.
Sources
- Notice served on bogus directors as Companies House changes come into force, GOV.UK / Companies House, 18 November 2025
- Verify your identity for Companies House, GOV.UK guidance, Companies House, first published 8 April 2025, updated 30 April 2026
- When you need to verify your identity for Companies House, GOV.UK guidance, Companies House
- Statistics at Companies House, GOV.UK / Companies House
- Identity verification for Companies House, GOV.UK collection, Companies House, first published 9 April 2025
- Companies House approach to non-compliance with mandatory identity verification, GOV.UK / Companies House, first published 17 November 2025, updated 5 December 2025
- Economic Crime and Corporate Transparency Act 2023, section 64: Identity verification of persons with significant control, legislation.gov.uk, as enacted