Association of Practising Accountants

Insolvency Service's First Prosecutions Herald New Era of Identity Verification Enforcement

Regulation

The Insolvency Service's first prosecutions on 17 September 2026 signal that Companies House identity verification is now actively enforced, with November 2026 marking a critical compliance deadline for directors.

Companies House has issued fresh warnings to directors to verify their identities with Companies House following the first Insolvency Service prosecutions on 17 September 2026. This landmark enforcement action marks a watershed moment for accountants and company directors alike, signalling that the identity verification regime introduced under the Economic Crime and Corporate Transparency Act 2023 is moving from compliance expectation to active prosecution.

What the prosecutions mean for your practice

The Insolvency Service prosecutions demonstrate that the UK government is taking identity verification breaches seriously.

Identity verification became mandatory on 18 November 2025, sparking a 12-month transition period at the end of which existing directors must have confirmed their identity with Companies House. That transition deadline is now approaching in November 2026, and the first enforcement actions suggest that HMRC and the Insolvency Service will pursue non-compliant directors with vigour.

For accountants advising director clients, this is a critical moment to audit compliance. Any director who has not yet verified their identity through Gov.UK One Login faces potential prosecution. The Insolvency Service's willingness to prosecute sends a clear signal: this is not a soft deadline with voluntary compliance expectations.

The broader identity verification landscape

The prosecutions sit within a wider economic crime prevention framework.

The Economic Crime and Corporate Transparency Act will bring in new responsibilities for those running limited companies, allowing Companies House to play a more significant role in tackling economic crime and supporting economic growth, leading to greater transparency and more accurate data.

However, Companies House has postponed by a further year the introduction of mandatory identity verification for individuals filing documents at Companies House (presenters), together with the related requirement for third-party agents to register as Authorised Corporate Service Providers (ACSPs), with these measures delayed from November 2026 to no earlier than November 2027, and Companies House will give at least six months' notice before they take effect. This two-tier timeline means directors face an immediate deadline this November, whilst the filing agent regime will follow in 2027.

Practical steps for accountants

Practitioners should now:

  1. Audit director compliance – Contact all client companies and confirm that directors have completed identity verification through Gov.UK One Login.
  2. Manage your own compliance – If you act as a company director yourself or manage trusts with corporate trustee status, ensure your identity is verified.
  3. Advise on the presenter regime – Whilst filing agent enforcement is deferred to 2027, clients who file documents themselves (rather than through agents) should understand that their own identity verification will eventually become mandatory.
  4. Flag the November deadline – Make clear to clients that November 2026 marks the end of the transition period for existing directors. Non-compliance beyond that date exposes directors to prosecution by the Insolvency Service.

Why this matters now

The prosecutions represent a shift in enforcement culture. For the first time, the Insolvency Service is actively pursuing individuals who fail to comply with identity verification requirements. This is not merely a technical filing requirement: it reflects government determination to rid the UK company register of shell entities and enhance transparency. Accountants who help clients navigate this requirement will reduce litigation risk and demonstrate proactive governance.

The takeaway is simple: November 2026 is not a soft deadline. It is a fixed compliance boundary, policed by prosecution. Advisers should treat it with the same urgency as a Self Assessment filing deadline or a PAYE/National Insurance payment due date.


Caveat: This is an AI-assisted summary; readers should verify all figures and timelines against Companies House and Insolvency Service official sources.

Further reading