# Companies House identity verification for RMC directors: the transitional period ends on 17 November 2026

> The 12-month transitional period for director identity verification ends on 17 November 2026. What an RMC or RTM company must file, and what a late one risks.

- Page to cite: https://aeolookup.com/block-management/companies-house-identity-verification-rmc-directors-17-november-2026/
- Publisher: AEO Lookup (https://aeolookup.com/)
- Section: Block and property managers, Running the firm
- Published 1 October 2026
- Key fact: The transitional period for Companies House identity verification is the 12 months beginning with 18 November 2025, so it ends on 17 November 2026. A company cannot file its confirmation statement unless every director is verified; a residents' management company with a confirmation date of 31 October 2026 must file by 14 November 2026, and from the next day an unverified director commits an offence by acting. An agent filing for 30 such companies pays £1,500 a year in filing fees at £50 each online.
- Sources: Economic Crime and Corporate Transparency Act 2023 (Commencement No. 6 and Transitional Provisions) Regulations 2025, SI 2025/1118, regulations 4 and 5; Companies Act 2006 ss 154, 167M, 853A and 1012 (legislation.gov.uk); GOV.UK guidance on verifying your identity for Companies House, when you need to verify, personal codes, the confirmation statement and people with significant control; Companies House approach to non-compliance; Insolvency Service and Companies House press release of 17 September 2026; Companies House "Changes to UK company law" site; all read 2026-10-01.

The transitional period for Companies House identity verification ends on 17 November 2026, twelve months after the rule became law on 18 November 2025. By then every residents' management company (RMC) and right to manage (RTM) company should have filed a confirmation statement carrying a verified identity for each director. Volunteer directors of a block are caught in the same way as the directors of any trading company.

**Free tool on the page:** Director identity verification email maker. It runs in the browser at https://aeolookup.com/block-management/companies-house-identity-verification-rmc-directors-17-november-2026/#tool and asks for no sign-up.

## What the rule asks, and of whom

| Person | What they must do | When |
|---|---|---|
| Director in post before 18 November 2025 | Verify, then give their Companies House personal code | In the company's next confirmation statement during the transitional period |
| Director appointed since 18 November 2025 | Verify before the appointment is filed | With the appointment filing |
| Person with significant control (PSC) who is also a director | Give the code a second time, for the PSC role | Within 14 days starting the day after the confirmation statement date |
| PSC who is not a director | Give the code | In the first 14 days of their birth month |
| The company secretary, or an agent who files | Nothing yet | Companies House says no earlier than November 2027, with at least six months' notice |

Verification is free through GOV.UK One Login: by app, by security questions, or at a Post Office after entering photo ID details online. An Authorised Corporate Service Provider, such as an accountant, can do it and may charge. The director receives a personal code, which belongs to the person and not to the company. A director of three RMCs gives the same code in three confirmation statements.

## Which blocks have a PSC

A PSC is anyone with more than 25% of the shares or voting rights. In most RMCs each flat holds one share or one vote, so the test is a count of flats.

| Flats, one share each | Each member holds | PSC? |
|---|---|---|
| 2 | 50% | Yes |
| 3 | 33.3% | Yes |
| 4 | 25% | No: not more than 25% |
| 24 | 4.2% | No |

A converted house of three flats has three PSCs, each with a 14-day window of their own. A block of four or more equal shares has none.

## One portfolio, worked through

A managing agent is company secretary to 30 RMCs with three directors each: 90 directorships to track.

1. Fees. A confirmation statement costs £50 online and £110 by post. Thirty online filings are £1,500 a year; by post they would be £3,300.
2. One company's dates. Its confirmation date is 31 October 2026. The statement must be delivered within 14 days after the review period ends, so by 14 November 2026.
3. The block on filing. GOV.UK says a company will be unable to file its confirmation statement unless all its directors are verified. One missing code out of three holds up the filing.
4. After the deadline. Under the transitional regulations, the ban on acting while unverified starts the day after the statement is delivered or, if it is not delivered, the day after the delivery period ends. For this company that is 15 November 2026.
5. The last ones. A company whose confirmation date is 17 November 2026 must file by 1 December 2026.

## What a late company risks

- An individual who acts as a director while unverified commits an offence under section 167M of the Companies Act 2006, and so does a company that lets them.
- A company that does not file its confirmation statement can be fined up to £5,000 and struck off.
- When a company is dissolved, its property passes to the Crown as bona vacantia under section 1012. For an RMC that owns the freehold, that includes the freehold.

Companies House and the Insolvency Service announced the first convictions on 17 September 2026. Three directors were fined between £80 and £307, plus costs. One of them had verified his own identity and was fined for failing to take reasonable steps to stop an unverified co-director acting. Two of the three had signed company accounts while unverified. Section 167M also says the offences are the only consequence: what an unverified director did as a director remains valid.

A director who will not verify can resign before the statement is filed, since the duty covers only people who are directors at that time. File the resignation first, and remember a private company must keep at least one director.

## What to do this month

1. List every company you file for, its confirmation date and its directors.
2. Mark which directors have a personal code. Ask them; you cannot verify on their behalf unless your firm is an authorised provider.
3. For blocks of two or three flats, list the PSCs and their 14-day windows, which show on the Companies House register.
4. Send the email below six weeks before each confirmation date.
5. Chase at three weeks. Where a code is still missing at one week, ask the board whether that director is staying.
6. Keep the codes as you would bank details, in the company secretarial file and not in general email.

> Subject: Action needed before [date]: verify your identity for [company name]
>
> Dear [name],
>
> The law now requires every company director to verify their identity with Companies House. [Company name] must file its yearly confirmation statement by [date], and we cannot file it until every director has done this.
>
> Please verify online through GOV.UK One Login (search "verify your identity for Companies House"). It is free. You will be given a personal code of 11 characters. Send that code and your date of birth to [secure contact], not by replying to this email.
>
> If you would rather step down as a director, tell us by [date] so we can file that first.

GOV.UK says a director can share the code with someone who files on their behalf, and that Companies House may ask for the date of birth to check the details match.

An incoming agent should ask for this list at [handover](https://aeolookup.com/block-management/managing-agent-handover-checklist-taking-over-a-block/). The company's own filings are separate from the service charge accounts, which have their own rules, set out in our guide on [whether service charge accounts need an audit](https://aeolookup.com/block-management/do-service-charge-accounts-need-to-be-audited/).

This is general information, not legal advice.

## Short answers from this page

**When do directors of a residents' management company have to verify their identity with Companies House?** Directors in post before 18 November 2025 must be verified by the time their company files its next confirmation statement in the 12-month transitional period, which ends on 17 November 2026. The company cannot file unless every director is verified. Verification is free through GOV.UK One Login, and acting as a director unverified after the company's deadline is an offence.

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General information for UK small firms, not legal, tax or financial advice.