By Naomi Rich, COO of ProSec
13th May, 2026
When the PSC regime came into force in April 2016, it felt like a seismic moment for UK corporate transparency. Nearly a decade on, the mandatory identity verification (IDV) regime under the Economic Crime and Corporate Transparency Act 2023 is — on paper — an even bigger shift. For the first time, every director, PSC, and person filing on behalf of a company must prove they are who they say they are before Companies House will accept what they file.
Six months into the mandatory phase, it is a good moment to ask the obvious question: is it working?
By the end of March 2026 — just over four months into the mandatory phase — verified identities had reached 28.49% of the relevant population, up from 6.27% at the end of December. That is a meaningful acceleration, and a more reassuring trajectory than the early-December figure suggested. A 12-month transition window was always going to produce a long tail, with the bulk of verifications clustering around confirmation statement dates. The shape of that curve is now visible.
The more interesting question is whether the curve continues to bend the right way. Getting from 28% to something close to 100% in the remaining seven months is a different exercise. The early adopters — the well-advised, the recently appointed, those with confirmation statements due — are largely through. What remains is the harder cohort: dormant company directors, long-serving PSCs who file little and engage less, overseas office-holders and the substantial middle of the register that simply hasn’t got round to it yet. None of those groups will be moved by the same things that moved the first 28%. Whether Companies House and the ACSP network can bring that tail in is the real test of the next six months — and the answer is genuinely uncertain.
What the headline numbers don’t capture is the operational friction that IDV has introduced in the back office. A pattern has emerged that deserves more airtime than it has had: people are getting verified, and then discovering that the director or PSC information already on the register doesn’t match the identity they’ve just verified. A date of birth transposed, an address that was never quite right.
The only route to fix it is a second filing — and those second filings can take several days if not weeks to work their way through Companies House. In a compliance environment where deadlines are unforgiving and confirmation statements wait for no one, a delay in corrections is not a minor inconvenience. It is a real commercial problem.
To its credit, Companies House has responded. ACSPs can now correct mistakes made during the verification process itself, which removes at least one category of second filing from the queue. That is a sensible, practical intervention, and more of them will be needed. The regime was always going to expose the accumulated untidiness of the register — what it wasn’t designed to do was bottleneck on its own clean-up.
The honest answer is that, given a twelve-month transition window, most directors and PSCs will eventually get verified. The tail will clear. What happens after that is the more interesting question: once the stock of existing office-holders is through the gate, IDV becomes a quieter, steadier obligation — triggered only on new appointments. In that sense, the hard part of the rollout is now, not later.
But the genuinely open question is what Companies House does on 19 November 2026 if the number still isn’t 100%.
This is the test the regime has been building towards. Verification without consequence is just a database update with extra steps. The ECCTA gives Companies House real powers — financial penalties, annotations on the register, and ultimately the ability to treat unverified filings as invalid — but powers on the statute book are not the same as powers exercised at scale. A handful of test cases will not shift behaviour. A wave of enforcement against thousands of non-compliant directors might.
That is the circle the regime has to square. Too light a touch and IDV ends up as a compliance obligation with a reputation for being ignorable. Too heavy a hand, without the operational capacity to handle the fallout, and the correction queue becomes a justice problem, not just an inconvenience.
Six months in, the foundations are broadly sound. The real verdict on IDV won’t be written on 18 November 2026. It will be written in the six months after, in how Companies House chooses to enforce — and whether it can.
If you have any questions about what this means for you and your company, please contact us on contact@prosec-cosec.com
