Papers Please: Identity verification requirements for corporate trustees of UK Pension schemes

Background

From 18 November 2025, UK company directors must comply with the identity verification requirements under the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”).

ECCTA, which received Royal assent in October 2023, is designed to prevent the abuse of UK corporate structures, tackle economic crime, and improve corporate transparency. When fully implemented, it will overhaul the way Companies House works: changing it from a passive recipient of information to a more active gatekeeper over company formation and a custodian of more reliable data. Identity verification constitutes an integral part of this.

Further identity verification obligations will follow later, including in relation to corporate PSCs (Persons with Significant Control) and individuals filing documents at Companies House.

These obligations will apply to corporate trustees of pension schemes, and this briefing sets out the legal and practical implications.

Identity verification for directors of trustee companies

From 18 November 2025, individuals will be prohibited from acting as a director without having verified their identity. There will be transitional provisions, giving existing directors up to 12 months to verify their identity.

• Directors appointed before 18 November 2025 will need to ensure they have gone through identity verification before the company’s next confirmation statement is filed.
• Directors appointed on or after 18 November 2025 (including on the incorporation of a company) will need to have verified their identity before their appointment.

Failure to comply with the verification obligations is a criminal offence (punishable by a fine), committed by the individual director, the company, and the company’s officers. Acts of the unverified director, however, are not affected and remain valid.

Identity verification for corporate Persons with Significant Control (PSCS)

Trustee companies (particularly those which were incorporated as companies limited by shares) may have a corporate PSC, otherwise known as a “relevant legal entity” (RLE). This will typically be the wholly owning shareholder. The existence of the company’s RLE should have already been filed at Companies House.

While the identify verification obligations will come into force for individuals who are PSCs from 18 November 2025, Companies House have confirmed that the obligations will apply to RLEs from a later date. When the obligations come into force, RLEs will need to nominate a “relevant officer”, whose identity has been verified.

There will be a transitional period for existing RLEs to comply. This is expected to be 28 days from the "appointed day" (a date to be specified in regulations, in due course); however Companies House may adjust this.

Failure to comply will also be a criminal offence, committed by the RLE and its officers. Importantly, this is not an obligation on the trustee company; however trustee companies may want to ensure that their RLE is taking steps to be compliant (particularly if the RLE is based overseas, or has limited secretarial capacity).

Individuals filing documents at Companies House

In addition to identity verification, Companies House is changing who can file documents on behalf of companies. In Spring 2026, restrictions under ECCTA are expected to come into force which will limit who can file documents on behalf of companies to:

• An employee or officer of the company, whose identity has been verified;
• An employee or officer of a corporate officer of the company (e.g. an employee or director of a professional trustee company acting as a director), whose identity has been verified; and
• An authorised corporate service provider (ACSP). These are third party companies that are subject to anti-money laundering supervision and have been registered with Companies House for the purposes of carrying out verification services and document filing.

Once the restrictions come into force, individuals filing documents at Companies House on behalf of a company will need to declare the capacity under which they are filing the document, and confirm that their identity has been verified. A failure to comply with either the capacity requirement or the verification requirement will likely invalidate the filing.

Identity verification: a user's guide

Since 8 April 2025, individuals have been able to voluntarily complete identity verification. Verification can be undertaken by four different methods, depending on the individual’s residence and available identification documents:

• The gov.uk “One Login Check” app – This is likely the simplest method, and allows for verification to be completed via the app using one of the relevant forms of ID (for example, a biometric passport – of any nationality).
• The gov.uk “One Login” web service – Verification via the web portal can be completed using one of the relevant UK IDs, and may involve answering some additional questions.
• The gov.uk “One Login” face to face service – Essentially this is verification, in person, at the Post Office, by appointment. Individuals using this will need a relevant form of ID, as well as a UK home address.
• An authorised corporate service provider – As noted above, an ACPS will be able to carry out verification for individuals. This may be necessary where the individual does not have the relevant forms of ID for the above methods, and/or a UK home address.

Once verified, individuals will receive a confirmation from Companies House, and an 11 digit “unique identifier” code, which can be provided as evidence that verification has been completed.

The verified status will apply to all an individual’s appointments. This means individuals will not need to verify themselves for each directorship.

Getting ready - practical steps

For directors in place on 18 November 2025:

• Check when the trustee company’s confirmation statement is due to be filed. If it’s before 18 November 2025, then you can note the next filing after 18 November 2025 as the deadline for compliance for existing directors. If it’s shortly after 18 November 2025, then consider an early filing, before 18 November 2025, to provide more time for compliance.
• Consider voluntary verification to avoid the risk of non-compliance.
• Check the Companies House guidance on identity verification, and make sure that you have a relevant form of ID, and have access to the requisite technology to complete verification.

For trustee director appointments on or after 18 November 2025:

• Identity verification could form part of the trustee director selection process. Ensure verification is complete before any appointment is formally made.

Check who files documents at Companies House for the trustee to establish whether they can still file documents once the restrictions come into force, and if so, whether they'll need to go through identity verification.

Check the trustee company’s filings at Companies House to help identify the RLE. If no RLE has been filed, consider if one should be. If there is an RLE:

• Keep an eye out for further updates from Companies House regarding the date that the obligation will come into force.
• Ensure the RLE is aware of its obligations and has processes in place to ensure compliance.

You may also listen to our PensionsPod on identity verification, which provides a deep dive into this topic at: UK PensionsPod: Economic Crime and Corporate Transparency Act 2023.

Authored by Dominic Starke.