Director and PSC Identity Verification: What’s the Difference?

Since 18 November 2025, identity verification has been a legal requirement for UK company directors and People with Significant Control (PSCs). But being a director and being a PSC are different legal roles, and the identity-verification process is not identical for each. The distinction is especially important for founders who hold both positions.

A person who is the sole director and sole shareholder of a UK company will normally be both a director and a PSC. They need to understand that their identity verification must be connected to each role separately, even though they generally only need to complete the underlying identity check once and receive one Companies House personal code.

This guide explains what director and PSC identity verification means, how the two processes differ, when each person must provide their personal code, what happens if verification is missed, and what the rules mean for overseas founders.

What Is Companies House Identity Verification?

Companies House identity verification is a process designed to establish that an individual is genuinely who they claim to be. The requirement was introduced under the UK's corporate transparency reforms to reduce fraud, improve the accuracy of the Companies House register and make it harder for individuals to use companies for unlawful purposes. Identity verification can generally be completed:

• Online through GOV.UK One Login
• Through an Authorised Corporate Service Provider (ACSP)
• Using an approved identity document and verification process

Companies House states that identity verification can be completed from any country. For online verification, an eligible biometric passport from any country can be used, alongside other accepted identification documents. After successful verification, the individual receives a unique Companies House personal code.

That code belongs to the individual, not to the company. If the same person is a director of several companies, they normally verify their identity once and use the same personal code for their different appointments.

Director vs PSC: The Fundamental Difference

The simplest way to understand the distinction is to start with the roles themselves.

A director runs the company

A company director is legally responsible for participating in the management of the company and complying with directors' duties. A director may or may not own shares. For example:

• Sarah is appointed director.
• Sarah owns no shares.
• David owns 100% of the shares but is not a director.

Sarah is a director but not automatically a PSC. David may be the PSC because he controls 100% of the shares, even though he is not a director.

A PSC owns or controls the company

A Person with Significant Control is an individual who meets one or more statutory conditions relating to ownership or control. This can include someone who:

• Owns more than 25% of the shares
• Holds more than 25% of the voting rights
• Can appoint or remove a majority of the board
• Exercises significant influence or control in circumstances covered by the PSC rules

Therefore, director status and PSC status are separate concepts. The same person can hold both roles, but one does not automatically create the other.

The Identity Verification Is Also Role-Specific

This is where many founders become confused. Suppose James is:

• The only director of ABC Ltd
• The sole shareholder of ABC Ltd
• The company's PSC

James generally only needs to complete the identity verification check once. However, Companies House requires him to connect his verified identity to both his director role and his PSC role. Companies House specifically states that if someone is both a director and a PSC of the same company, they must provide their personal code separately for each role. So there are two concepts to keep separate:

Identity check: generally completed once.

Role confirmation: completed separately for each relevant role. This distinction is particularly important when completing Companies House filings.

How Director Identity Verification Works

Existing directors

For existing directors, the current transition process requires the director to provide their Companies House personal code with the company's relevant confirmation statement.

Companies House says a company will be unable to file its confirmation statement unless all its directors have been verified and the required personal codes have been provided. This makes director verification a company-level compliance issue as well as an individual responsibility.

New directors

If someone is becoming a director of a new company, identity verification forms part of the incorporation process. If someone is being appointed as a director of an existing company, they must verify their identity before the appointment is notified to Companies House. The practical sequence is therefore broadly:

1. Complete identity verification.
2. Receive the Companies House personal code.
3. Provide the code through the relevant appointment or incorporation process.
4. Companies House connects the verified identity to the director role.

A person should not assume that simply being listed as a director means the verification requirement has been satisfied.

How PSC Identity Verification Works

PSC verification follows a different timetable. Every PSC must verify their identity and provide their Companies House personal code for their PSC role. Companies House gives each PSC a 14-day period in which to provide the required verification details. The timing depends on the PSC's circumstances.

For example, if someone is both a director and a PSC, their PSC verification deadline is handled separately from the process for confirming them as a director.For an existing PSC who is also a director, the 14-day PSC period starts from the day after the company's confirmation statement date.

For an existing PSC who is not a director, the 14-day period is based on the person's month of birth as recorded on the Companies House register. A PSC who becomes a PSC after 18 November 2025 can provide their personal code when first added to the register or within the applicable 14-day period.

Director and PSC Identity Verification Compared

The most important takeaway is that one individual can have one verified identity but multiple Companies House roles.

What Happens If You Are Both a Director and PSC?

This is probably the most common situation for small owner-managed companies. Consider a typical one-person company:

Michael

• 100% shareholder
• Sole PSC
• Sole director

Michael completes his Companies House identity verification and receives a personal code. He then needs to ensure that the code is correctly provided for:

1. His director role
2. His PSC role

Companies House explicitly states that a person who is both director and PSC must provide their personal code separately for each role. The important point is that Michael does not need two separate identity checks simply because he has two roles. He has one verified identity but two separate role confirmations.

What If You Are a Director but Not a PSC?

You still have to verify your identity as a director. For example:

• Alice owns 100% of the company.
• Bob is appointed as director.
• Bob owns no shares and has no other relevant control rights.

Alice would normally be the PSC. Bob is still required to complete director identity verification because his legal role is separate from PSC status. This is an important point for startups that appoint professional managers, family members or external directors. Not being a shareholder does not remove a director's identity-verification obligation.

What If You Are a PSC but Not a Director?

The reverse also applies. Imagine:

• Daniel owns 70% of the company.
• Emma owns 30%.
• A professional director manages the company.
• Neither Daniel nor Emma is a director.

Daniel and Emma would normally both be PSCs based on their shareholdings. They must comply with the PSC identity-verification requirements even though they do not manage the company as directors. This illustrates why companies should maintain two separate questions: Who manages the company? and Who owns or controls the company? The answers may be different.

How Do You Verify Your Identity?

Companies House provides several routes for identity verification. One route is online verification through GOV.UK One Login. Companies House says eligible photo identification can include:

• A biometric passport from any country
• A UK photo driving licence
• Certain UK biometric residence documents
• Other accepted documents depending on the verification route

Verification can also be completed through an Authorised Corporate Service Provider (ACSP), such as an appropriately authorised accountant, solicitor or company formation professional. For overseas founders, the ability to verify from outside the UK is particularly relevant. You do not generally need to travel to Britain simply to complete Companies House identity verification.

What Is the Companies House Personal Code?

After successfully verifying your identity, Companies House provides a unique personal code. Think of it as a way of linking your verified identity to the Companies House roles you hold. The code is:

• Personal to you
• Not the company's code
• Used to confirm your verified identity
• Reusable for relevant Companies House roles
• Something you should keep secure

Companies House advises individuals to share their personal code only with people they trust when someone is filing on their behalf. If an accountant or authorised agent handles Companies House filings for you, they may need the code to complete the relevant filing.

What Happens If Identity Verification Is Not Completed?

Failing to comply can have consequences. Companies House states that continuing to act as a director without completing the required identity verification can constitute an offence. A company may also be in breach where its directors have not complied.

For PSCs, failure to comply with identity-verification requirements can also constitute an offence and may result in a financial penalty or fine. Companies House may also display a note against the person's name on the public register.

There are also practical consequences. For directors, Companies House states that a company will be unable to file its confirmation statement unless all directors have been verified. The reforms are therefore not merely about proving identity once. They form part of the company's ongoing compliance framework.

Does Identity Verification Make Your Personal Information Public?

Not everything submitted during identity verification becomes publicly available. Companies House states that supporting information provided for identity verification does not form part of the public register and is not made available to the public through its services.

This is different from information that Companies House already publishes about directors and PSCs. For example, certain director and PSC information appears on the public register, while sensitive verification evidence is handled separately. Identity verification should therefore not be confused with publishing a copy of someone's passport or other identity document.

What Does This Mean for Overseas Founders?

For international entrepreneurs, the distinction between the two roles is especially useful. A non-UK resident can potentially be:

• A UK company director
• A UK company shareholder
• A PSC
• Both a director and PSC

The fact that someone lives outside the UK does not by itself prevent them from holding these roles. Companies House allows identity verification from outside the UK, including online verification using an eligible biometric passport from any country. However, company identity verification is only one part of operating a UK company from overseas. Tax residence, banking, immigration, employment and other regulatory questions are separate issues.

A Practical Checklist for Founders

If you are setting up or managing a UK company, use this simple checklist.

If you are a director

• Complete Companies House identity verification.
• Keep your personal code secure.
• Provide the code through the required director filing.
• If you are a director of multiple companies, make sure verification is connected to each appointment.
• Monitor your confirmation statement requirements.

If you are a PSC

• Complete identity verification.
• Obtain your personal code.
• Check your applicable 14-day PSC deadline.
• Provide the code through the PSC verification service.
• Keep Companies House informed when your PSC details or nature of control changes.

If you are both

• Complete the identity verification once, where applicable.
• Use the same personal code.
• Confirm your identity separately for the director role.
• Confirm your identity separately for the PSC role.
• Do not assume completing one role's requirement automatically completes the other.

Frequently Asked Questions

Is director identity verification the same as PSC identity verification?

The underlying identity verification is generally the same process, but the person's identity must be connected to each relevant Companies House role separately. A person who is both a director and PSC must provide their personal code separately for each role.

Do I need two Companies House personal codes if I am both a director and PSC?

No. You generally receive one personal code after successfully verifying your identity. The same code is then used to confirm your identity for the relevant roles you hold.

Can a director be a PSC?

Yes. Many owner-managed companies have the same person acting as director, shareholder and PSC. The roles remain legally distinct.

Can a PSC be someone who is not a director?

Yes. A shareholder or other person who meets the PSC conditions can be a PSC without being a director.

What is the deadline for PSC identity verification?

Every PSC has a 14-day period for providing their personal code and verification statement. The exact dates depend on factors including when they became a PSC and whether they are also a director.

Do overseas directors have to verify their identity?

Yes, if they fall within the Companies House identity-verification requirements. Verification can be completed from outside the UK, including through the online process using eligible identification.

Does identity verification need to be repeated every year?

Generally, no. Companies House says that in most cases you only need to verify your identity once and should not repeat the process unless instructed to do so. However, your personal code must be used to confirm your verified identity for the relevant roles.

What happens if a director does not verify their identity?

A director who continues to act without complying with the identity-verification requirement may be committing an offence. The company may also face compliance consequences, including being unable to file its confirmation statement where required director verification has not been completed.

What happens if a PSC does not verify their identity?

A PSC who fails to comply may be committing an offence and may face a financial penalty or fine. Companies House may also display a note against the person's name on the public register.

Can an accountant or company formation agent verify my identity?

An Authorised Corporate Service Provider (ACSP) can carry out identity verification for clients if authorised by Companies House and meeting the relevant requirements.

Conclusion

Director and PSC identity verification are closely related, but they are not the same company role and should not be treated as the same filing requirement. A director is responsible for managing the company, while a PSC is an individual who meets the legal conditions for significant ownership or control. One person can be either role, both roles, or neither.

The practical rule for founders is straightforward: Verify your identity once where applicable, receive your Companies House personal code, and then make sure that code is correctly connected to every role for which you are required to confirm your identity. If you are both a director and PSC of the same company, Companies House specifically requires the personal code to be provided separately for each role.

For overseas founders, the process can generally be completed without travelling to the UK, making the new identity-verification requirements manageable even when the company is operated remotely. As the Companies House reforms continue to expand, treating identity verification as part of normal company administration not a one-off incorporation task will help founders keep their company records accurate and avoid preventable compliance problems. IncorpUK, a UK company formation and management platform for global founders, can be part of the wider infrastructure founders use to manage a UK company remotely.