Companies House identity checks: the deadline every café director must hit

An email lands while you are unstacking chairs. Companies House, it says, needs you to verify your identity within 24 hours using the one-time reference number below.
Forward it to phishing@companieshouse.gov.uk, then delete it. That email is on Companies House's own list of scams.
But keep the thought. Identity verification is real, free and quick, and if your café company's next confirmation statement date falls between now and 17 November, your deadline is weeks away.
What changed, and who it catches
Since 18 November 2025, under the Economic Crime and Corporate Transparency Act 2023, Companies House has required directors and people with significant control (PSCs) to verify who they are. It applies UK-wide.
You are in scope if you are:
- a director of a limited company, as most owners of a café company are;
- a member of a limited liability partnership (LLP), which counts as the equivalent of a director;
- a PSC, usually someone holding more than 25% of the shares or voting rights.
You can ignore it as a sole trader or an ordinary partnership, which register with HMRC, not Companies House. Add it to the admin side when you weigh up sole trader against limited company for a café.
Your deadline is your confirmation statement
There is no single national deadline. Of 18 November 2025, Companies House says: "This date is not a deadline. It marks the start of a 12-month transition period". The period ends on 17 November 2026; within it, each existing director's date is set by their company's next confirmation statement.
The confirmation statement guidance is blunt: "We will not accept your company's confirmation statement until all directors have verified their identity." The filer ticks a box confirming each director has verified and gives their personal codes.
Your statement has two dates:
- the confirmation statement date, the end of your review period;
- the due by date, 14 days later, the last day you can file on time.
Search for your company on the free Companies House register: the overview shows both dates, and the People tab shows each director's verification status and each PSC's due dates. I would verify well before the first date. Which of these are you?
- Filed a confirmation statement on or after 18 November 2025? Your directors have verified, or Companies House would not have accepted it. Check the PSC step below was done too.
- Next statement date between now and 17 November? You are in the last batch; the last due by dates run to 1 December 2026.
- Statement date in the last 14 days, nothing filed? Not late yet, but your PSC window is open. Verify today, then file and do the PSC step before the due by date.
- Due by date passed, nothing filed? You are late. Verify and file now.
If you own more than 25%: the second step
Most owner-directors are also PSCs: two roles, two actions. As a director, your code goes into the confirmation statement. As a PSC, you give it separately through the "Provide identity verification details for a PSC" service, "within a 14 day period, starting from the day after the company's confirmation statement date."
You cannot do it before that window opens, and filing the statement early does not move it. A PSC who is not a director, such as a silent investor, has a different window in the transition year: the first 14 days of their birth month. For most that has passed; for an October or November birthday it is still to come. Any PSC can ask for a 14-day extension once their window opens and before it closes.
How to verify, for free
The direct route is GOV.UK One Login, online or in the app. Companies House's guidance asks for:
- photo ID: a biometric passport from any country, a UK photo driving licence (full or provisional), or a UK biometric residence permit, card or Frontier Worker permit;
- your current address and the year you moved in.
The app will not take an expired passport, but a DVLA licence that expired in the last 90 days is fine. No suitable photo ID? UK residents may be able to use bank or building society details, a National Insurance number and security questions instead. Or finish at a participating Post Office after entering your photo ID details on GOV.UK. Neither route takes expired documents.
Verifying direct with Companies House "is free of charge", and the app's ID check averaged 2.4 minutes between March and June 2025. An Authorised Corporate Service Provider, such as your accountant, can verify you instead and "may charge a fee". Do it once: one code works for every company and role.
At the end you get an 11-character personal code for the person who files your confirmation statement.
Worked example: two directors, a late October date
Illustrative company: Harbour Street Coffee Ltd. Two directors, both appointed in 2021: the owner with 60% of the shares and her partner with 40%. Each holds more than 25%, so both are PSCs too. It last filed in October 2025, before the rules began. The confirmation statement date is Tuesday 27 October 2026, and the aim is to be ready by then.
The sums, counted from Tuesday 29 September:
- Due by date: 27 October + 14 days = Tuesday 10 November.
- Time left: 28 days to the statement date, 42 to the due by date.
- PSC window: starts the day after 27 October and runs 14 days, so Wednesday 28 October to Tuesday 10 November.
- A date of birth correction, if needed, comes first. Started online on 29 September, a full 20 working days clears on 27 October, the statement date itself.
| When | What |
|---|---|
| This week | Check the register dates and both dates of birth; start any correction today |
| This week, if the records match | Both directors verify through GOV.UK One Login |
| Once verified | Both personal codes go to whoever files, often the accountant |
| 27 October to 10 November | File the confirmation statement, ticking the director box (£50 online, if the annual fee is due) |
| 28 October to 10 November | Each director gives their code again through the PSC service |
| From 11 November | An unverified director still acting commits an offence, and the company and the other director can too |
A correction started on 13 October could run to 10 November, the due by date, leaving everything else for one day. I would not plan on it.
What happens if you miss it
Under section 167M of the Companies Act 2006, "An individual must not act as a director of a company unless the individual's identity is verified". If an unverified director acts, the company and every officer responsible commit an offence too. The court fines differ: uncapped in England and Wales, capped in Scotland and Northern Ireland.
On 16 September 2026 three directors were fined at City of London Magistrates' Court: £80, £166 and £307, each with £85 costs and a victim surcharge. Late confirmation statements were part of the convictions.
The £307 fine went to a director who had verified, convicted for failing to take reasonable steps to stop his unverified co-director acting. In an owner and partner café company, you answer for each other.
The fines were small, but they were criminal convictions. Companies House sends default letters, can issue financial penalties and annotate the public register, and "may pursue enforcement action without further notice". In serious cases, such as repeat offending, it says prosecution "may lead to criminal conviction, director disqualification and fines."
Separately, not filing the confirmation statement is its own offence, and the company may be struck off. Companies House quotes fines of up to £5,000; in England and Wales the law sets no upper limit.
The emails that are not from Companies House
Companies House's scam page lists real examples: a Gmail account telling you to verify, the 24-hour "reference number" email, one with an HMRC logo, and "Know Your Customer" verification requests.
Report emails to phishing@companieshouse.gov.uk, and calls or letters on 0303 1234 500. It says it will never call to ask for passwords, bank details, your authentication code or "details of directors or company officers".
New directors and new companies
Directors appointed since 18 November 2025 have to verify before they act, with no transition year. A new company gives each director's personal code in the registration filing, so if you are incorporating a separate company for site two, verify first.
Buying a café company usually means new directors, so add verification to your due diligence on an existing café.
This week
- Look up your company on the register: note the statement date, the due by date and the People tab.
- Check every director's date of birth in WebFiling or with your accountant, and start any correction today.
- Every director verifies through GOV.UK One Login, today if your next statement date is on or before 17 November.
- Send the personal codes to the person who files, and diary the PSC window next to your weekly books half hour. Check any non-director PSC's own window on the People tab.
- Tell whoever opens the post and the inbox that verifying direct with Companies House is free.
It is not on the list of licences and registrations for a café, because it is a duty on you as a director rather than a licence for the business. A little time this week is cheaper than any letter that follows.
Ed O'Brien has run Hunters Cake Company for 17 years across cafés in Witney, Burford, and a bakery in Carterton, Oxfordshire. He's building Brikly - modular tools that give independent café owners the same data the big chains have, without the big chain price tag.