How to track Companies House identity verification across all your clients

If you manage Companies House compliance for a portfolio of clients, you have probably written "18 November 2026" on a wall planner and told yourself you have until then. You don't. That date is the end of the transition window, not the deadline for most of the people you look after. The real deadlines arrived the moment mandatory identity verification went live, and they land on a different date for almost every director and PSC on your books.

This guide explains how Companies House identity verification deadlines are actually triggered, why a single planner date will let people slip through, and how to build a tracking system that scales from twenty clients to two thousand. Every date and rule below is drawn from current Companies House and GOV.UK guidance, with sources listed at the end.

Why "18 November 2026" isn't your real deadline

18 November 2026 is the end of a 12-month transition window, not a universal cut-off. Mandatory identity verification began on 18 November 2025, and from that point each existing director and PSC inherited a personal deadline tied to their own company filings or birth month. Treat the end date as the only date and you will miss earlier individual windows, many of which fall months before.

Companies House opened voluntary verification on 8 April 2025, and more than one million people verified early, ahead of the rules becoming compulsory. That head start matters: the people who have not yet verified are now on the clock, and the clock runs at a different speed for each of them. For a single company director, that is one date to remember. For a firm acting on behalf of hundreds of companies, it is hundreds of overlapping dates with three different trigger rules.

How Companies House identity verification deadlines actually work

Verification deadlines are set by one of three triggers, depending on whether the person is a director, a director who is also a PSC, or a PSC who is not a director. Each trigger uses a different reference point: the confirmation statement date, a 14-day window after that date, or the person's birth month. Knowing which rule applies to which client is the whole job, and we break the rules down further in the three verification windows.

Existing directors: the confirmation statement trigger

An existing director must give their Companies House personal code with the company's next confirmation statement filed on or after 18 November 2025. The personal code is issued once per person when they verify, and it then covers all of that person's appointments. Crucially, the obligation attaches to each company separately, so a director of five companies satisfies it five times, against five different confirmation statement dates.

Directors who are also PSCs: the 14-day window

A person who is both a director and a PSC has a sharper rule: a 14-day window that starts the day after the company's confirmation statement date. Companies House gives a worked example. If the confirmation statement date is 31 March 2026, the person must verify between 1 and 14 April 2026. This is a hard window, not a "by year-end" obligation, and it is easy to miss if you are only watching the wall planner.

PSCs who are not directors: the birth-month window

A PSC who is not also a director verifies in the first 14 days of their birth month, as shown on the public register. If the register records a date of birth of March 1990, the window runs from 1 to 14 March. This rule has nothing to do with the company's filing dates at all, which means a single client company can contain people with completely unrelated deadlines.

New appointments since 18 November 2025

For incorporations and new appointments made on or after 18 November 2025, verification is required up front. A new director or PSC must verify before the appointment is registered, and a newly added PSC must verify when first added to the register or within 14 days of a direction letter from Companies House. These cases are usually the easiest to manage because they sit inside your normal onboarding flow.

The early confirmation statement trap

The most expensive misunderstanding is assuming you can file a confirmation statement early to get verification "done." For a director-PSC, the 14-day verification window is anchored to the confirmation statement date, not the date you actually file. Filing the CS01 a month early does not move the window. It is worth its own walkthrough, which we give in the early confirmation statement trap. The person still has to verify in the 14 days after the official statement date, and if you have mentally ticked them off, nobody will.

Picture a firm that batches its March confirmation statements in January to clear the desk. Every director-PSC in that batch still has a verification window in the days after their March statement date. The filing is done; the verification is not; and the only thing connecting the two is a date that has already scrolled off the to-do list. Multiply that across a portfolio and you have a slow drip of missed windows that nobody is watching.

How many deadlines does a 200-client firm actually have?

Confirmation statement dates are spread roughly evenly across the year because they fall on each company's incorporation anniversary, and birth months are spread across all twelve months too. So a portfolio's verification deadlines don't cluster on one date; they smear across every month of the year. The chart below illustrates the shape of the problem for a firm with around 200 client companies.

This is why the "one big deadline" mental model fails. There is no quiet period to prepare for a November rush, because the work was never going to arrive in November. It arrives a few clients at a time, all year, and the only way to stay on top of it is to track each person's trigger individually.

How much of the population still needs to verify?

Companies House counts more than seven million existing directors and PSCs in scope to verify during the transition. More than one million had verified voluntarily by the time the rules became mandatory in November 2025. That leaves the large majority still to be verified across the transition window, which is the population your clients sit inside, and the reason their verification status keeps changing under you.

How to track verification you didn't perform

You do not have to carry out a client's verification to know whether it has happened. When a director or PSC verifies, a verification start date is recorded against their appointment in Companies House's public company data. That date sits on the appointment record for any company, which means a firm can monitor verification status across every client's officers by reading Companies House data, without becoming an Authorised Corporate Service Provider and without touching the verification process itself. We go deeper on this in how to track verification you didn't carry out.

This matters because in practice your clients will verify through several routes. Some you may verify directly if your firm is an ACSP. Many directors will verify themselves through GOV.UK One Login without telling you. Unless you are reading the register, those self-verifications are invisible to you, and you cannot tell a "done" client from an "overdue" one. Reading the public signal closes that blind spot for the whole portfolio at once.

Spreadsheet versus a purpose-built tracker

A spreadsheet works for a handful of clients and quietly fails past a few dozen. The reason is structural: every row needs a different trigger rule, the dates move, and the register changes underneath you without notice. A column of "deadlines" is only correct on the day you typed it. A purpose-built portfolio tracker derives the rule and the status for you instead. The comparison below is the honest version of what most firms discover three months in.

A step-by-step system for tracking verification across your portfolio

Whatever tool you use, the workflow is the same five steps. Get these right and the question "who still needs to verify?" stops being a research project and becomes a glance at a dashboard. Here is the system, in the order you should build it.

1. List every in-scope person, not every company. Pull every director and PSC across your client base. The unit of tracking is the person-appointment, because one person can carry several deadlines.
2. Classify each person by trigger rule. Tag each as director, director-PSC, or PSC-only, and capture the relevant confirmation statement date or birth month. This is what turns a name into a deadline.
3. Read the current verification status. Check Companies House's public data for the verification start date on each appointment, so you know who is already done before you chase anyone.
4. Sort by status and proximity. Surface overdue and due-soon people first. A traffic-light view (verified, due soon, overdue) makes the queue obvious.
5. Refresh on a schedule. The register changes constantly, so a one-time pull is stale within weeks. Re-read it regularly and let the statuses move on their own.

That last step is the one firms skip and the one that matters most. Identity verification is not a project with an end date; it is a rolling status that has to be re-checked, because the population is verifying continuously and your clients are part of it.

Frequently asked questions