The Economic Crime and Corporate Transparency Act 2023 introduces new mandatory requirements for company directors, members of limited liability partnerships, people with significant control and those making filings at Companies House to verify their identity.
When IDV has been successfully completed, Companies House will issue an 11-character unique identifier known as a Companies House personal code to the individual in question. This personal code will not be disclosed publicly by Companies House and should be kept securely. If an individual verifies via an ACSP, they will receive an email containing their personal code. If they verify directly with Companies House, they will see the personal code on screen (and should screenshot it for their records). They should then be able to view their personal code in the “manage account” section of their Companies House account.
This personal code will be used to connect an individual’s verified identity with the records at Companies House for each of the roles they hold..
How is your personal information held?
The new IDV legislation will extend the list of materials unavailable for public inspection at Companies House to include documents and statements delivered to Companies House in connection with IDV requirements but see the approach regarding ACSPs set out below. To find out how personal information is stored and used when you verify your identity through Companies House using GOV.UK One Login, see the GOV.UK One Login privacy notice. Notably, in relation to information security, this confirms that systems and processes have been set up to prevent unauthorised access or disclosure of information – for example, using varying levels of encryption. Any third parties must also keep all personal information they process on behalf of the Governmental Digital Service secure. Users are reminded of the need to choose a strong password for their GOV.UK One Login and ensure they keep it secure.
If using an ACSP to undertake IDV, the ACSP is under an obligation to keep records of all the evidence and information used to verify someone’s identity. This must be kept for seven years from the date it completes IDV and includes copies of the documents checked, evidence of the identity checks completed and records of any failed verification attempts. In terms of the information submitted to Companies House by an ACSP, Companies House guidance confirms that once a person connects their personal code to Companies House records, the public register will show their identity verification statement that will include the person’s name, ACSP name, name of the Anti-Money Laundering supervisory body the ACSP is registered with and the date the identity checks were completed.
When might reverification be required?
Disclaimer
This article is intended for general information purposes only and does not constitute legal advice. For advice specific to your situation, please contact our team at T & M Legis for a consultation with our Legal Experts.
