Companies House identity checks need a record for every role

A director who has verified their identity can still have an unfinished Companies House submission. Keep one identity record for each person and a separate action record for every company role. That separation makes the next required filing visible, especially when someone is both a director and a person with significant control, or PSC. S1 S4

This guide is for UK company secretaries, owner-directors and administrators coordinating existing individual directors and PSCs during the identity-verification transition. It turns current Companies House guidance into a practical reconciliation record. The example is fictional and is not a determination of any real company’s obligations.

Companies House generally expects a person to verify once. The resulting personal code belongs to that individual, and is used again to connect their identity with each appointment. A message saying “I have verified” therefore answers the person-level question. It does not establish that every required company-role submission has been completed. S1 S4

For an existing director, the code is supplied with the company’s next confirmation statement. A director of several companies must complete that step for each. For a PSC, a separate service takes the personal code and a verification statement. Where the same person is both director and PSC of one company, retain two actions. S2 S3

For an existing PSC who is also a director of the same company, the PSC window runs for 14 days from the day after the confirmation statement date. Filing the statement early does not move that window. An existing PSC who is not a director of that company uses the first 14 days of their birth month. Check the person’s actual dates in the Companies House register or PSC service before assigning the task. S2 S3

These existing-role rules should not be copied onto every new appointment. A PSC added after 18 November 2025 can provide the code when added or within 14 days of being added. New director appointments and incorporations have their own filing step. The transition began on 18 November 2025; that fact alone does not identify an individual’s due date. S2 S4 S5

Use a stable internal person reference to avoid counting the same individual twice. Keep the verification status and a restricted evidence reference at person level. In the role register, record the company identifier, role, applicable date trigger, displayed window, responsible filer, submission state and evidence reference. The register is an operational control proposed here, not a prescribed Companies House form.

Assume a review on 12 October 2026. Person A is the sole director and a PSC of Company Alpha, and a director of Company Beta. Person B is a PSC of Alpha but is not its director. Both people and all four roles existed before 18 November 2025. Both people have verified. Neither PSC has protected information or an extension. These are invented role assignments, not a method of deciding who qualifies as a PSC.

Alpha’s relevant confirmation statement date is 20 October 2026. Its statement was filed early on 12 October with A’s director details accepted. For this example, A’s PSC window is shown as 21 October to 3 November. Beta’s next statement date is 31 October and its filing remains open. B’s birth month is October and their PSC window is 1–14 October. The dates and acceptance evidence below are fictional inputs.

The immediate queue contains B’s PSC task. A’s Alpha PSC task belongs in a future queue with a reminder for 21 October. The Beta filer has a separate open filing task. Alpha’s completed director filing cannot close any of those three rows.

The dual-role PSC window is 21 October through 3 November inclusive: 11 days in October plus 3 in November equals 14. The 12 October filing event is not the starting date. B’s birth-month window is 1–14 October, also 14 calendar days. These calculations check the example; a live register or service date must still be checked for a real person. S2

Two of two people are verified, or 100%. One of four role submissions is complete, or 25%. Neither figure is a legal compliance score. One remaining row is not yet in its window, and the Beta row needs its actual filing deadline checked. Report the action states and dates alongside any count; a single percentage loses the distinction between upcoming, open and overdue work.

Assign closure to the person responsible for the filing. They should record the company and role submitted, the actual submission date, the outcome and the location of the acceptance evidence. A prepared form or a code received from a director is an intermediate state. If a submission is rejected, keep the row open and retain the rejection and later correction separately.

Keep raw personal codes out of a broadly shared task list. Companies House says to keep the code safe and permits sharing it with people who file on the individual’s behalf. Use a restricted channel or record for that purpose; give the wider register an evidence reference and named custodian. This access design is an editorial recommendation, not a claim that a particular software product is legally required. S4

If details do not match, use the official correction route rather than marking the record complete. A date-of-birth error or incorrect agent-supplied details may need correction. For a suspected compromised code, Companies House provides a route to request replacement. S4

The ordinary PSC service cannot be used where the PSC’s personal information is protected or a protection application is awaiting a decision. Check the applicable route with Companies House. The service also allows a request for a 14-day extension before the verification deadline passes. Record an extension request and its outcome separately; this example assumes no extension and does not treat a request as approval. S3

Overseas companies, corporate roles and other phased groups need their own scope check. Being outside the UK personally is also different from representing an overseas company. Do not reuse this example as an exhaustive legal checklist, a PSC ownership test or an interpretation of penalties. For a disputed role or deadline, obtain advice appropriate to the company’s circumstances.

Reconcile the role list whenever an appointment or PSC entry changes, before the next relevant filing, and when Companies House changes its guidance. Retain the prior position and date the correction. For a distributed filing team, the related QSE guide on document control at the point of use explains how to check that people retrieve the current instruction; its UAE setting does not make it a source for UK filing law.

At the end of the review, every open row should identify the person, company, role, date basis and next action. That is the useful output: a filer can see what remains to be done without interpreting “verified” as a blanket completion status.

QSE Advisory · AI-assisted research and drafting. Reviewer and Assessor: Laraib Naveed Ahmad. General information based on the sources checked on 12 October 2026; verify the applicable record and current guidance before acting.

This article is general information. Verify current requirements and seek qualified advice for your specific circumstances.

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