So, Are You Actually Verified? What ECCTA Means for Share of Freehold Directors

Can I ask you something slightly personal? Are you, Companies House's own public record of who runs your building's company, actually verified as you? Not "I filled in a form once," verified, in the specific, new, slightly bureaucratic sense the law now means. A surprising number of directors I've come across don't know the honest answer, and that's sort of the interesting bit.

What's this "identity verification" thing even for?

Officially, it's the Economic Crime and Corporate Transparency Act 2023 doing what it says on the tin, making it harder to run a UK company as someone who doesn't exist. Companies House got new powers, and from 18 November 2025 those powers include a legal requirement, under new sections inserted into the Companies Act 2006 (section 1110A defines what counts as "verified"; section 167M sets out the actual director duty), that a director's identity is checked and confirmed. There's now an offence for continuing to act as a director without it. Which is a strange sentence to write about the person who does the AGM minutes for a four-flat block, but there it is.

Okay, but when do I actually have to do this?

Here's the bit that trips people up: there isn't a date circled on a calendar somewhere. If you're already a director, verification has to be done before your company's *next confirmation statement filed after 18 November 2025* gets accepted. Companies House simply won't take the filing until every director on the record, not just whoever's doing the typing, has verified. New directors have it blunter still: no verification, no appointment, full stop, from day one.

For a share of freehold company where confirmation statements tend to be one person's quiet annual chore, that's worth sitting with. It's not your verification status that can hold up the filing. It's whichever co-director moved abroad two years ago and has read approximately none of the emails since.

And what about the person who owns most of the shares?

People with significant control, PSCs in the local dialect, are on their own separate clock, which is easy to miss if you assume director verification covers everyone. A new PSC has 14 days from being notified to verify. An existing PSC who's also a director gets 14 days from the confirmation statement date. An existing PSC who isn't a director gets 14 days from the first day of their birth month, which is a genuinely odd sentence to have typed, but is, as far as I can tell, entirely real.

So what actually happens if someone just... doesn't?

Practically, the first thing that happens is nothing dramatic: the confirmation statement won't go through, which starts the same overdue-filing clock, and eventually the same strike-off risk, as any other missed statement. But there's a sharper edge underneath it, the personal offence for acting as a director unverified, which is a different category of problem to a late-filing letter. If a co-director's gone quiet on this the way people go quiet on everything else, it's worth treating it exactly like you'd treat any other unresponsive director: document what you've tried, and have the honest conversation about whether a resignation is more realistic than another six months of waiting.

Where this leaves the person who "does the admin"

If you're the one who ends up filing for your building, this is one more thing to check before you file, not instead of the things you already check. It's worth looking at whether your register of directors is genuinely current at the same time, since a stale list makes it harder to know who even needs verifying, and at what else ECCTA changed about statutory registers, since it's the same piece of legislation doing several things at once.