Directors of block companies must verify their identity by 17 November: what boards need to do now
Every director of a freehold, RTM or residents' management company who was in post before 18 November 2025 must verify their identity with Companies House by the company's next confirmation statement. The 12-month transition ends on 17 November 2026, and the first prosecutions have happened.
What happened
Since 18 November 2025, identity verification has been a legal requirement for company directors and people with significant control, under the Economic Crime and Corporate Transparency Act 2023. Companies House says that date was the start of a 12-month transition period, not a deadline.
The transitional rules say that for each director who was already in post, the company must deliver an identity verification statement at the same time as it delivers its next confirmation statement during the transition period. That period is 12 months from 18 November 2025, so it ends on 17 November 2026.
On 17 September 2026 the Insolvency Service announced its first convictions for these offences: three directors of two companies were fined at City of London Magistrates’ Court. “There is no option to opt out,” its senior criminal lawyer said.
What it means for your building
Freehold companies, right to manage companies and residents’ management companies are ordinary companies, and the people on their boards are often volunteers who have never had to file anything themselves. The rules make no exception for them. If your block’s company has three to six resident directors, each of them needs to be verified, and the company needs their personal codes when it files its confirmation statement.
The Insolvency Service also made the point that directors are responsible for each other: it says the prosecutions show directors must make sure unverified people do not carry on acting as directors for the company. So one director who has not verified is a problem for the whole board.
Many residents’ management companies have no person with significant control, because each flat holds one share. Yours may be different, so check the register.
What to do now
- Look up your company on the Companies House register and note the date its next confirmation statement is due.
- Ask each director to verify now, through GOV.UK One Login with photo ID such as a passport or UK driving licence, or through an Authorised Corporate Service Provider such as an accountant. Companies House also lists routes using bank details or a Post Office visit.
- Collect each director’s personal code before the confirmation statement is filed.
- If a director cannot or will not verify, discuss with the board whether they should step down, and minute the decision.
- From now on, ask anyone joining the board to verify before they are appointed.
This is general information, not legal advice. Check the Companies House guidance for your company’s own dates.
How Freeholdpilot helps
Freeholdpilot puts the company’s filing dates, including the confirmation statement, on the board’s calendar of legal deadlines, and records board decisions and votes, so the board can see who has done what and when.
Questions
Does this apply to volunteer directors of a residents' management company?
Yes. The rules apply to every director of a UK company, paid or unpaid. Most freehold, RTM and residents' management companies are companies limited by shares or by guarantee, so their directors are covered.
What is the deadline for a director who was already in post?
An existing director's identity has to be verified when the company files its next confirmation statement during the transition period, which runs for 12 months from 18 November 2025 and so ends on 17 November 2026. If your company's confirmation statement has already been filed without it, check the Companies House guidance straight away.
What about a director who joins the board now?
Since 18 November 2025, a new director must verify their identity before they can be appointed and act as a director.
What happens if a director will not verify?
The Insolvency Service says directors who act without verifying risk prosecution, and that fellow directors also have a responsibility not to let an unverified person carry on acting. A director who does not want to verify may need to step down. Take advice if you are unsure.
Sources
- Companies House: Verify your identity for Companies House (updated 30 April 2026)
- Insolvency Service: Directors warned to verify identities with Companies House following first Insolvency Service prosecutions (17 September 2026)
- legislation.gov.uk: Economic Crime and Corporate Transparency Act 2023 (Commencement No. 6 and Transitional Provisions) Regulations 2025, regulation 4
This is general information about the law in England and Wales unless it says otherwise, not legal advice for your building. For advice, speak to a solicitor or ask us to introduce one of our partner firms.
