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FOUNDRS×Joshua Leigh & Co

Seven million founders.Seven million quiet deadlines.

The UK's biggest company compliance change in a generation never had one big day. It has millions of small, scattered ones, and the founders caught in the middle of it are paying for that design.

Produced by FOUNDRSPublished August 202612 min read
Introduction

A deadline nobody shares.

On 18 November 2025, Companies House made a change that touched almost every company in the country. Identity verification for directors and people with significant control (PSCs) became a legal requirement under the Economic Crime and Corporate Transparency Act 2023, replacing a voluntary system that had run since April 2025.

The scale is hard to overstate. Companies House estimates that 6 to 7 million people will need to verify their identity by mid-November 2026, a compliance exercise touching roughly one in ten UK adults, carried out almost entirely through self-service government technology.1

Compare it to Making Tax Digital. MTD has a single flagship date: hundreds of thousands of sole traders and landlords file their first quarterly update on the same day, which is exactly why that date made the news. And even then, only three in ten sole traders say they understand what MTD actually requires of them; almost one in five are more confident naming the football transfer deadline than their own.5

Identity verification doesn't get a single loud day at all. There is no date that 6 to 7 million people share. Your deadline is tied to your company's next confirmation statement; if you're a PSC, it's a two-week window inside your own birth month. Multiply that across millions of companies and you don't get one loud deadline. You get millions of quiet ones, each easy to miss precisely because almost nobody else is thinking about theirs at the same moment you're thinking about yours.

On the government's own numbers, it is going well. As of 31 March 2026, Companies House had issued 3.81 million personal codes, and 90% of those who completed the check found the process easy.1 But “verified” is doing a lot of work in that sentence. This report is about the gap underneath it, not because the check itself is difficult, but because a deadline nobody experiences at the same time is a deadline almost no one notices until it's overdue.

The numbers that matter
6–7m
people who must verify by November 2026, each on their own individual deadline1
3.81m
personal codes issued as of 31 March 20261
~37%
of PSCs verified by late June 2026, with 1,465,993 already past their due date2
90%
of those who completed the check said it was easy1

That last pair is the whole story. Nine in ten found it easy and yet little more than a third of PSCs had crossed the line, with close to 1.5 million already overdue. Both things are true at once. This report explains why: not because the check is hard, but because the deadline is invisible by design.

Section 01

What actually changed.

For decades, becoming a UK company director required little more than a name and an address. Identity verification is designed to make it harder to set up companies or appoint directors using fake or stolen identities, and easier to link multiple directorships to one person. The principle is broadly uncontested; even critics accept the register was too easy to abuse.

The mechanics are where it gets fiddly. Verification happens once, producing an 11-character personal code that is tied to you as an individual, not your company, and reused across every role you hold. There are two routes: free, directly through GOV.UK One Login, or through an Authorised Corporate Service Provider (ACSP) such as an accountant or solicitor (often a paid for service).

The deadline isn't a single date for existing directors. It's tied to the company's next confirmation statement, and the absolute backstop for existing officeholders is 18 November 2026, though most hit the confirmation-statement trigger well before that. In practice, that means 6 to 7 million people are working against 6 to 7 million different dates. Nobody is watching one shared clock, and advisers report the same pattern: “uncertainty stems from the 12-month transition period... rather than a single deadline.”6

Most people go it alone. Of the 3.81 million verified by the end of March, ACSPs accounted for 783,000, meaning roughly four in five people completed the check themselves through the government service rather than paying an agent to handle it.1

4 in 5

people verified so far did it themselves, direct through GOV.UK, not through an accountant.1

Section 02

Sized for the people it hits hardest.

A change like this lands unevenly, and the reason isn't really about size. Larger, more established companies usually have a company secretary, an IT function, or a standing relationship with an accountant, someone whose job includes watching deadlines on their behalf. They barely notice this happening. The people who do notice are the ones with nobody doing that watching for them.

75%

of private-sector businesses have no employees other than their owner.8

948,000

of those one-person businesses are limited companies, and so in scope for verification.8

That's most of the UK's private sector. For a business like that, there's no company secretary to flag a confirmation statement, no separate finance team to catch a PSC window before it closes. The founder is the director, the PSC, and the only person available to track both, which is exactly the problem this report keeps circling back to, just at a smaller scale: nobody watching one shared clock, and for millions of businesses, nobody watching their own individual one either.

This is the same audience our earlier research identified: solo founders and micro-business owners who described their first year of company admin in a single word, “terrifying”, caught off guard again and again by obligations nobody had flagged in advance. Identity verification is the newest instance of exactly that pattern, made worse by its own design: a sole director-owner is, in the rules' eyes, both a director and a PSC, two obligations, tracked separately, with nobody but them to notice either.

“Terrifying.” That's how founders in our earlier research described their first year of company admin. Every one of them was caught off guard by something they'd never heard of.

Section 03

Where things actually stand.

The government's progress is real. But with around 3 million individuals still to verify and only about five months until the transition period ends, the job is far from complete and the remaining group is not a random slice of the register.

PSCs in particular are lagging badly. Analysis of Companies House's own published register data by contributors to AccountingWeb's Any Answers forum found that as of 22 June 2026, only 36.5% of PSCs had verified (2,477,916 against 6,786,804 still outstanding), of whom 1,465,993 already had a filing due date that had passed. Directors are ahead but far from done: 49.1% verified (4,685,908 of 9,537,543 on record), with 1,492,287 already overdue.2

Enforcement is no longer hypothetical. In the period to 31 March 2026, Companies House had already sent two million email nudges and more than three-quarters of a million default letters, and begun casework that could lead to court cases and financial penalties.1 The consequence isn't abstract, either: an unverified director blocks the company's confirmation statement entirely, and failing to file a confirmation statement is itself a criminal offence carrying fines and potential strike-off, so a single unverified director on a company with several can stop the whole filing.

1,465,993

PSCs were already past their verification due date by late June 2026, and directors aren't far behind, with 1,492,287 of their appointments overdue too.2

Companies House doesn't dispute any of this. Its own annual report puts 2025 to 26 customer satisfaction at 75%, against an 82% target it says it missed largely because of “the change of identity verification”, down from just over 80% the year before. Digital service availability stayed strong, at 99.6%, comfortably beating its own target. Read together, those two numbers say something precise: the platform held up. The experience of using it didn't, for enough people to move the organisation's own scorecard.7

Section 04

The honest account of verifying.

The headline satisfaction figure is genuine. The average completion time for the GOV.UK ID Checking App is under two and a half minutes, and plenty of people breeze through. The failures matter precisely because they happen against that backdrop, and because they cluster in telling ways. Every quote below is from a named member of the public commenting on Companies House's own blog.3

I've spent an hour and a half trying to verify my identity. The app keeps kicking me out… I feel like resigning my directorship.
Isabel C.Volunteer director of a community benefit society3

Technical friction

The most common complaint is getting trapped in loops that never resolve. One IT-literate director described finally getting through only after “four hours, three helpdesk calls and an awful lot of very hot tea.” Another was blunter: “The system is not fit for purpose and should be taken down until it can be resolved. I am IT literate.” A third ran the whole journey twice, was bounced between departments, and left on hold for 45 minutes before the call failed: “Shocking… I'm trying to run a business here.”3

The double-verification trap

Because a sole director-owner is both a director and a PSC, the same person often has to submit their code twice, in two different places, a design quirk that catches people repeatedly. It's the single most common source of confusion in adviser forums, and it disproportionately affects exactly the one-person companies least likely to have someone to explain it. Part of the problem is structural, not just confusing: a director enters their code as part of filing the confirmation statement, but a PSC does not submit as part of that same filing, so there is no equivalent prompt telling a sole director-owner a second step even exists. “Many did not realise a second submission is required,” says Joshua Finn CA, founder of ACSP practice Joshua Leigh & Co.4

The record you didn't know was wrong

A smaller, harder-to-fix failure has nothing to do with the app or the website. Where Companies House holds an incorrect date of birth for a director or PSC, that person can complete verification and receive their personal code, then find the code doesn't work when they come to verify themselves as director or PSC on the confirmation statement itself. Correcting it means paper forms, sent by post, to fix the underlying record first: slow enough, in the experience of ACSP accountants, that “the submission deadline was missed.”4

The one-person company treated like a corporation

Directors of tiny, non-trading entities keep asking why the burden is identical to a large firm's. A director of a self-managing block of three flats put it plainly: “We don't trade and we don't make a profit. We're not a multi-million pound company, why are we being treated like one?”

The ACSP route isn't always the safety net it looks like

When the digital route fails, people are pointed to an accountant or agent, but that hand-off can dead-end too. One director who called the first firm on the official list reached “a very unhappy accountant” who said she was “only doing this for her own clients” and asked to be removed from the list. Companies House's own reply confirms the gap: being on the list “is not a guarantee they will be able to verify your identity”, so a person may need to contact more than one.

Section 05

Why this keeps happening.

Companies House didn't sit on its hands. Over the year, it sent more than 39 million emails and reminders, and general awareness of the company-law changes rose from 40.5% to 77%, over 80% among accountants and solicitors.7 Awareness went up. Completion still lagged. That gap is the reason this section exists.

Behind every one of those statistics sits an accountant fielding the calls. This section draws on the frontline experience of one such firm: Joshua Leigh & Co, a chartered accountancy and registered audit practice on the high street in Barnet, north London, a team of 19 acting for owner-managed businesses, partnerships and private clients, and a registered ACSP since verification became mandatory. Its account of the process has nothing to do with the check itself being hard.

A guidance gap, even for the professionals

The firm heard about the changes early, in 2025, from a mix of online sources and Companies House's own email notices. What it didn't get was a connected route through them. Companies House's webinars for ACSPs, it says, “covered the upcoming changes at a high level,” but “none of the ones we attended set out clearly the step-by-step process that would actually need to be completed.”4

If the professionals meant to guide clients through this weren't given a connected, step-by-step account of what to do, only high-level briefings, it's no surprise the founders relying on them fared worse still.

Awareness was never the missing piece

The firm's own response was the best available under the circumstances, and still fundamentally manual: tell every client through the regular newsletter, then make the team available by phone and email. It worked well enough by its own measure: under 10% of clients needed the firm to verify them entirely as their ACSP, and a wider group, taking the total needing some kind of hands-on support to around 30%, needed talking through it by phone.4

How much help did clients need to get verified?

One ACSP practice's own client base4

70%
20%
10%
Got through it with little or no inputTalked through it by phoneNeeded the firm to do it for them

One ACSP practice's own client base4

But “worked well enough” meant one-to-one conversations, not a system. Looking back, the firm says the thing it would change is exactly that: “It would have been beneficial for both us and the client if we provided a thorough step-by-step guide… rather than simply making clients aware of what would be required.” Awareness was never the missing ingredient. Connected, actionable information was.4

The real burden isn't the check

Ask where the burden actually sits, and the answer isn't the identity check. “The ID verification itself hasn't been too much of a burden,” the firm says. “It is keeping on top of, and tracking, the various deadlines that has caused the most issues.” The same individual can be carrying multiple deadlines tied to the same company, one as director, one as PSC, “with no simple way to identify this.”4

Multiply that across millions of company relationships, each with its own confirmation statement date and, for PSCs, a two-week window tied to an individual's birth month, and you get exactly what the numbers show: not one deadline people are failing to meet, but millions of quiet, individual ones nobody has a connected way to track.

Multiple deadlines for the same person should never have been the design, and the two-week PSC window makes no sense from a user's perspective. Neither reflects how business owners actually engage with Companies House.
Joshua Finn CAFounder and Director, Joshua Leigh & Co (ACSP)4
Two smaller, technical failures

On top of the deadline-tracking problem, two specific technical failures came up often enough that the firm developed a standard answer to each.

Has a workaround

The smartphone app

The first was the smartphone app used to run the check. The fix was routing around it, advising clients with “no access to a smartphone or tablet,” which sent them to the website instead.4

No workaround

The wrong date of birth

The second, an incorrect date of birth sitting on the Companies House record, has no such workaround. It requires paper forms and the post, and by the time it's fixed, the filing deadline has often gone.4

It's the same conclusion this report keeps reaching from different directions: this was never really a story about who finds the check easy and who finds it hard. It's a story about a deadline structure that nobody, professional or founder, has ever had a connected way to see.

Section 06

This isn't the last one.

Identity verification is phase one, not the whole story. It's the first of several overlapping changes, each arriving with its own scattered, individual deadlines rather than one shared date, that steadily close off the informal, do-it-yourself ways of dealing with Companies House and HMRC.

No earlier than Nov 2026

Presenter verification & mandatory ACSP filing

Verification will extend to anyone who files at Companies House, and from no earlier than November 2026, third parties filing on a company's behalf will themselves need to be registered as an ACSP. In plain terms: an accountant or bookkeeper who isn't registered won't be able to file for their clients at all.

1 April 2028

Software-only accounts filing

After being paused in early 2026, the accounts reforms were confirmed for April 2028: from then, accounts must be filed through commercial software rather than the free web or paper routes, small and micro companies must prepare a full profit and loss account (though eligible ones can still choose not to publish it on the public register), and abridged accounts are removed.

1 April 2028

the date the free web and paper routes for filing accounts close for good.

Not well prepared

Joshua Leigh & Co is candid about what's ahead, too. Asked how well prepared the average small business owner is for presenter verification and software-only accounts filing, its answer is blunt: “As a whole, not well prepared for the upcoming changes.” It expects the practical effect to be that owner-managed businesses who have always filed for themselves start appointing an accountant they'd never previously felt they needed, “a genuine increase in compliance cost for the smallest businesses, not simply a change of process.”4

Each of these does the same thing: it shuts a manual, informal route and assumes the founder already knows what's coming.

What FOUNDRS was built to solve

The connected view that's been missing.

The founders caught out by identity verification aren't unusual, and the problem isn't that the check is hard. It's that nobody, not Companies House, not most accountants, not the founders themselves, has ever had one connected view of which deadline applies to which person, and when. Even a proactive firm like Joshua Leigh & Co ran that entirely by hand: a newsletter, then a phone call, repeated one client at a time.

FOUNDRS

Get organised, and stay that way.

Most founders spend their time buried in government portals, finding and chasing accountants, and juggling tools that were never designed to work together.

FOUNDRS fixes that. One place to start your business, manage your compliance and stay on top of everything that keeps it running. We'll handle incorporation, compliance and the admin that founders hate, leaving you free to build what matters. No jargon. No guesswork. No lengthy forms. Just smart automation that makes starting simple.

FOUNDRS is a registered ACSP.
Joshua Leigh & Co

The view from the front line.

This report was co-authored with Joshua Leigh & Co, a chartered accountancy and registered audit practice in Barnet, north London, and a registered ACSP. Their client data and frontline experience of walking business owners through verification shaped Section 05.

Practical check

The check that costs you nothing today.

If someone else files at Companies House on your behalf (an accountant, bookkeeper or formation agent) there's one question worth asking now: are you a registered ACSP? From November 2026, an unregistered agent won't be able to file for you at all.

GOV.UK

Check the Companies House list of registered ACSPs

Companies House publishes a list of Authorised Corporate Service Providers who have told them they are able to carry out identity verification.

View the list on GOV.UK

Companies House's own list is voluntary and not exhaustive, so “not found” isn't proof either way, always ask directly. You can check Companies House's ACSP guidance and register, or ask FOUNDRS directly. FOUNDRS is a registered ACSP.

Appendix

Notes & sources

This report draws on official Companies House data, independent register analysis, an on-the-record interview, and public comments, each sourced individually below.

  1. 1Companies House official identity verification statistics, published data to 31 March 2026.
  2. 2Analysis of Companies House published register data by contributors to AccountingWeb's Any Answers forum, as of 22 June 2026.
  3. 3Named members of the public commenting on Companies House's official blog, gov.uk.
  4. 4Written interview with Joshua Finn CA, Founder and Director, Joshua Leigh & Co Limited (registered ACSP), conducted for this report, July 2026.
  5. 5Survey of sole traders commissioned by Sage, reported in Professional Electrician, 9 July 2026.
  6. 6Carter Bells, "Confusion as Companies House rolls out identity checks for directors", 13 March 2026.
  7. 7Companies House annual report and accounts 2025 to 2026, published 13 July 2026.
  8. 8Department for Business and Trade, Business population estimates for the UK and regions 2025, published 2 October 2025.