US UK Accountants: Companies House ID Checks Explained

Companies House identity verification became a legal requirement on 18 November 2025. Every director, director-equivalent, director of an overseas company registered in the UK, and person with significant control must verify. A US-resident board member with no UK document can verify from anywhere in the world through an Authorised Corporate Service Provider, and receives a personal Companies House code.

For the US-resident founder, investor or non-executive who holds a seat on a UK board, this is the moment the UK register stopped accepting an unverified name. As US UK Accountants, the question Jungle Tax is asked most often is not whether the obligation applies — it plainly does, regardless of nationality or where you live — but how somebody in New York, Austin or San Francisco, holding a US passport and no UK address history, is supposed to satisfy a UK statutory identity check. The answer is more straightforward than the panic around it suggests, provided you understand which route you are eligible for and what evidence you must assemble before you start.

What the Companies House identity verification requirement actually is

The requirement flows from the Economic Crime and Corporate Transparency Act 2023, which converted Companies House from a passive filing repository into a body with powers to test the truth of what is filed. Identity verification is the centrepiece of that shift. The register has, for over a century, accepted a name and a service address at face value. It no longer does.

Two dates matter and both are on the record. Voluntary verification opened on 8 April 2025, allowing individuals to verify ahead of time and hold a code in reserve. Verification then became a legal requirement on 18 November 2025. Since that date, the identity of the individuals behind UK companies is something Companies House expects to have confirmed, not merely to have been told.

Companies House publishes the operative guidance itself, and it is worth reading in the original rather than through a summary: see Verifying your identity for Companies House on GOV.UK, together with the wider identity verification collection. Guidance in this area has been revised repeatedly since launch; the GOV.UK page, not a commentary page, is the version that governs you.

Who must verify their identity?

The categories captured are broader than "UK company directors", and the breadth is precisely where overseas individuals are caught unawares. Verification applies to:

• Directors of UK-registered companies, executive and non-executive alike. A non-executive seat carries the same obligation as a full-time managing role.
• Director-equivalents — members of limited liability partnerships, general partners, and managing officers who occupy an equivalent position under the relevant constitution.
• Directors of overseas companies registered in the UK. If your Delaware corporation, your Cayman fund vehicle or your Irish holding company has registered a UK establishment, its directors fall inside the regime even though the company itself is not a UK company.
• People with significant control (PSCs). This is the category that catches passive holders: a shareholder who has never attended a board meeting, never signed a filing and does not consider themselves involved in the company can still be a registrable PSC and can still be required to verify.
• Authorised Corporate Service Providers (ACSPs), and the individuals within them who carry out verification work.

Nationality is irrelevant. Residence is irrelevant. There is no exemption for individuals who have never set foot in the United Kingdom, no exemption for a US citizen, and no exemption for a director whose involvement is nominal. If you occupy one of the roles above, you verify.

Why does the standard verification route fail for US-resident directors?

Companies House offers a direct route through GOV.UK One Login. It is free, it is quick, and for a UK-resident holder of a UK passport or driving licence with a settled UK credit footprint it usually completes in minutes. For a US-resident director it frequently does not complete at all, for reasons that have nothing to do with the legitimacy of the person attempting it.

The recurring failure points we see are consistent:

• Document recognition. Automated chip-reading and facial-matching is tuned to documents the system expects. A US passport is a valid government-issued document, but the automated path can still return an unexplained failure to prove identity, with no stated reason and no obvious next step.
• Knowledge-based verification has nothing to work with. Where an automated document check is inconclusive, the fallback typically leans on a UK data footprint — UK credit file, UK address history, UK financial products. A US-resident director has none of it, so the fallback route has no data against which to test the claim.
• Delivery mechanics. Security codes sent to non-UK mobile numbers, letters posted to non-UK addresses, and services designed around UK-hours support all introduce friction that a UK resident never encounters.
• The Post Office route is geographically useless. The in-person alternative Companies House offers requires attendance at a UK Post Office branch. That is not a route for a director in Chicago.

None of this is a reason to conclude that verification is impossible from the United States. It is a reason to select the correct route at the outset rather than burning weeks on a channel that was never designed for you.

The ACSP route: verification from any country

An Authorised Corporate Service Provider is a business registered with Companies House and supervised by a UK anti-money laundering supervisory body, authorised to carry out identity verification and to tell Companies House it has done so. Accountancy firms, law firms and company secretarial practices sit in this category. Critically for an overseas board member, an ACSP can verify an individual who is located anywhere in the world. The provider must hold its UK registration and supervision; the person being verified does not have to be anywhere near the United Kingdom.

This is the route that resolves the US-resident problem. Rather than an automated system attempting to recognise your document and failing silently, a supervised professional carries out the check against the standard Companies House sets, records the evidence, and confirms completion to Companies House. Where the individual does not live in the UK, the check requires at least one government-issued document — for a US-resident director that is ordinarily the US passport, which the ACSP route can accept even where the automated channel could not process it.

What an ACSP will require from a US-resident director

Providers differ in process, but the evidential core is consistent. Expect to supply:

• A current government-issued photographic identity document. For a US-resident director this is normally the US passport; where a second document is requested, a state driver's licence or a further government-issued document is typically used.
• Evidence of your residential address as it will be held by Companies House. Note the distinction between your residential address, which is held but not published in full, and your service address, which appears on the public register.
• A liveness or facial-likeness check, usually performed remotely by video or through a secure application, matching you to the document.
• Your full legal name, date of birth, and any former names, exactly as they will appear against your appointment. Mismatches between the name on a US passport and the name recorded against a UK directorship are one of the most common causes of avoidable delay.
• Anti-money laundering onboarding at the provider itself, which is a separate exercise from the Companies House check and is frequently underestimated in the timetable.

The sequence, step by step

• Step one: Confirm which role or roles trigger the obligation for you — director, director-equivalent, overseas company director, PSC, or more than one of these across several entities.
• Step two: Establish whether the direct GOV.UK One Login route is realistically available to you. If you hold no UK document and no UK data footprint, do not spend three weeks proving that point; go to an ACSP.
• Step three: Engage an ACSP and complete its own client onboarding.
• Step four: Complete the identity check and provide the documentary evidence.
• Step five: The ACSP confirms to Companies House that it has verified you.
• Step six: Receive and secure your Companies House personal code, then ensure it is supplied wherever your appointments require it.

What is a Companies House personal code — and why is it yours, not the company's?

On successful verification you are issued a Companies House personal code: an eleven-character unique identifier. The single most important characteristic of that code is stated plainly in the GOV.UK guidance on Companies House personal codes for identity verification — the code is personal to you, not to your company or to a company you work for.

The practical consequences of that single sentence are larger than they first appear, and they matter disproportionately to individuals who sit on several boards:

• You verify once, as a person. The code travels with you across every appointment. A US-resident non-executive holding four UK directorships does not verify four times; they hold one code.
• The code survives your departure. It does not belong to the company that prompted you to obtain it, and it is not surrendered when you resign a seat.
• It is required where your appointments require it. The code is quoted in connection with directorships, appointments and PSC registrations, so it must be available to whoever files on your behalf.
• It must be kept secure. Treat it as you would any other unique personal identifier. Where verification was carried out by an ACSP, the code is issued to the email address supplied during verification — make sure that is an address you control personally, not a shared company mailbox you may lose access to.

If you verified through GOV.UK One Login, the code can be retrieved by signing in to your Companies House account and viewing it under account management, using the same email address you verified with. If you verified through an ACSP, the provider sends it to the address given at the time.

UK and US obligations compared: two registers, two different questions

US-resident directors routinely conflate the UK identity requirement with US reporting, or assume that satisfying one addresses the other. They are separate regimes with separate triggers, separate authorities and separate consequences.

Question	UK — Companies House	US — IRS / FinCEN
What is being tested?	That the individual behind a UK appointment is who they say they are	That a US person has reported their interests in, and authority over, a foreign corporation and its accounts
What triggers it?	Holding a role: director, director-equivalent, overseas company director, or PSC	Status as a US person combined with an officer, director or shareholder relationship, or signature authority over foreign accounts
Does residence matter?	No — nationality and location are irrelevant to the obligation	No — US citizens and green card holders are within scope wherever they live
Frequency	Ordinarily a one-off personal verification producing a durable personal code	Annual, alongside the US federal return and the FBAR where thresholds are met
What you receive	An eleven-character Companies House personal code	No identifier — the obligation is a filing, not a credential
Consequence of ignoring it	Statutory non-compliance, with enforcement action and restrictions on appointments and filings	Substantial information-return penalties, and an open statute of limitations in many cases

The cross-border point most guides miss: a UK board seat has US consequences

Almost every page written about Companies House identity verification stops at the UK border. That is where the genuine cross-border exposure begins for a US person, and it is why we treat a client's Companies House verification as a prompt to review the US side of the same appointment rather than as an isolated administrative errand.

Officer and director reporting on Form 5471

A UK limited company is a foreign corporation for US federal tax purposes. Certain US citizens and residents who are officers, directors or shareholders in certain foreign corporations are required to file Form 5471, under sections 6038 and 6046 — see the IRS page About Form 5471. The category that surprises people is the officer-and-director category, because it can be triggered by acquisition events at the shareholder level rather than by anything the director personally did. A US-resident non-executive who received no dividend, took no salary and holds no shares can still land inside a filing category by virtue of the office they hold and what other shareholders did during the year.

Form 5471 is an information return with a severe penalty regime, and an unfiled information return can leave the assessment period for the whole return open. This is the single most expensive thing a US-resident UK director tends to have missed, and it is a core part of our US tax return preparation work.

Signature authority and the FBAR

The FBAR reaches beyond ownership. A US person must report where they have "a financial interest in or signature or other authority over" at least one foreign financial account, where the aggregate value of those accounts exceeded USD 10,000 at any point in the calendar year — see the IRS guidance on the Report of Foreign Bank and Financial Accounts (FBAR). A director who is a signatory on the UK company's bank account can therefore have a personal FBAR obligation in respect of an account they do not own and from which they receive nothing. Directors of trading UK subsidiaries are caught by this constantly. Our FBAR penalty calculator gives an indication of the exposure where filings have been missed.

Where a UK board seat also creates a UK tax footprint

Directors' fees for duties performed in the United Kingdom, and the payroll treatment of a non-resident director attending UK board meetings, sit outside the identity verification regime entirely but arise from the same appointment. A US-resident non-executive who attends UK board meetings in person should establish the UK reporting position for those duties as a matter of course. That is return-preparation territory, and it belongs on the same checklist as your verification.

Directors of overseas companies registered in the UK

If a non-UK company has registered a UK establishment, its directors are inside the verification regime. This catches a great many US corporations that opened a UK branch rather than incorporating a subsidiary, and whose US-resident board never thought of themselves as having a UK filing footprint at all. The obligation attaches to the individuals, and Companies House sets out separately when directors of overseas companies must have confirmed their verification. Check the current position on the GOV.UK page covering when you need to verify your identity for Companies House, because timings differ by role and by entity type.

PSCs who never sit on the board

The PSC category is where wealthy individuals are most often caught by surprise. A person with significant control need not be a director, need not be involved in management and need not think of the company as theirs. Ownership of a sufficient shareholding, sufficient voting rights, or the right to appoint or remove a majority of the board can each be enough. A US-resident investor holding a meaningful minority stake in a UK company, through no vehicle and with no operational role, may well be a registrable PSC with a personal verification obligation and a personal code to obtain. Companies House publishes a dedicated route for PSC verification details, and PSCs who are not otherwise directors have their own timing rules.

What appears on the public register — and what does not

Privacy is a legitimate concern for HNW individuals, and the answer is reassuring. Verification does not publish your identity documents. The fact that an individual has verified is reflected against their appointment; the underlying evidence, and your residential address, are not published in full. Your service address remains the address that appears publicly, which is why choosing that address deliberately — and keeping it consistent across every appointment — is worth a few minutes of attention before you verify rather than after.

What happens if you do not verify?

Since 18 November 2025 this is not a best-practice recommendation; it is a statutory obligation. Companies House has published its approach to non-compliance, and the consequences run in two directions. There is the enforcement dimension — non-compliance can amount to an offence and attract financial penalties. There is also the practical dimension, which usually bites first: an unverified individual creates friction on appointments, registrations and filings, which in turn can stall a transaction, a financing round or an audit sign-off at exactly the moment speed matters. We have seen a deal timetable slip because a single US-based non-executive had not obtained a personal code and could not do so overnight.

A practical compliance sequence for the US-resident director

• Map every UK role you hold. Directorships, LLP memberships, overseas company appointments and PSC positions. Include entities you have forgotten about; dormant companies still have directors.
• Verify once, early, and hold the code. Because the code is personal and durable, obtaining it in advance removes it as a bottleneck for every future appointment.
• Use an ACSP if you have no UK document. It is the route designed for you and it operates internationally.
• Reconcile your name and address data first. Fix mismatches between passport, register entry and service address before verification, not after.
• Run the US side of the same appointment. Form 5471 exposure, FBAR signature authority, and Form 8938 reporting where applicable. If any of those have been missed for prior years, the correction route matters — our IRS streamlined filing work exists precisely for non-wilful historic non-compliance of this kind.
• Document the file. Keep the code, the verification confirmation, and the evidence pack somewhere that survives a change of company secretary or a change of email address.

How Jungle Tax approaches this

We are a specialist US and UK cross-border tax practice. Our work is return preparation and compliance: getting the filings right, and bringing individuals who have fallen behind back into compliance cleanly. When a US-resident client tells us they have been asked for a Companies House personal code, we treat it as the visible edge of a larger question — which UK appointments do you actually hold, and what has each of them been generating on the US side that has not been reported? For most of our clients the identity verification itself is the simplest part of the exercise. The five years of unfiled Forms 5471 sitting behind it are not.

If you hold a UK directorship, an equivalent office, or a significant UK shareholding and you are resident in the United States, we can help you establish exactly which obligations attach to you on both sides of the Atlantic and put your filings in order. To discuss your position in confidence, contact our cross-border team for a private consultation. Everything you tell us is confidential, and nothing is filed until you have seen and approved it. You can also review our wider US UK tax accountancy services or browse our other cross-border guides.