Director ID Verification at Two Weeks: ACSP Capacity, Rejection Patterns and the 12-Month Transition Clock

The mandatory phase of Companies House identity verification (IDV) began on 8 April 2026. Every new director, every new Person with Significant Control (PSC), and every new member of an LLP must now complete IDV before their appointment can be accepted on the register. Existing officeholders — an estimated seven million people — are inside a rolling 12-month transition that ties verification to the next confirmation statement filed by each company.

Two weeks in, the picture is messier than the policy timeline implied. This piece pulls together what the early data, the Authorised Corporate Service Provider (ACSP) market and the published guidance say about how the regime is actually working — and what company secretaries, sole directors and accountants should be doing this month rather than next quarter.

What changed on 8 April 2026

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) split Companies House reform into roughly four tranches. The 8 April 2026 commencement is the third and arguably the most consequential for day-to-day filing:

• New directors appointed on or after 8 April 2026 must have a verified status before the AP01 (or AP02 for corporate directors) is accepted.
• New incorporations (IN01) require all proposed directors and PSCs to be verified at the point of submission. Unverified subscribers cause the entire filing to bounce.
• New PSC notifications (PSC01) are subject to the same gate.
• Existing directors and PSCs must verify by the date their company files its next confirmation statement (CS01) on or after 8 April 2026 — giving most companies between one day and twelve months of runway.

The penalty for filing as an unverified person is a criminal offence under section 1110A of the Companies Act 2006 (as inserted by ECCTA), with civil financial penalties under the regulatory regime sitting alongside it. Companies House has been clear it will use civil penalties first and prosecution sparingly, but the offence sits on the books from day one.

The three verification routes, compared

IDV is route-agnostic in principle but very different in practice depending on whether you go direct, through an ACSP, or in person. The table below summarises the position as of mid-April 2026.

The free GOV.UK One Login route is the headline option, but it only works cleanly for UK-resident individuals with a recent biometric passport and a phone that can run the One Login app. For everyone else — overseas directors, those with older passports, anyone whose facial-recognition check has failed — the practical route is an ACSP.

ACSP capacity is the bottleneck

Companies House published the ACSP register on 18 November 2025. As of 24 April 2026 there are roughly 1,650 firms authorised — predominantly accountants, company secretarial agents, and a handful of specialist KYC platforms. That sounds like plenty until you do the arithmetic: against a stock of around seven million existing officeholders plus an annualised flow of ~600,000 new directors, the median ACSP would need to verify in the low thousands of people across the transition window.

The early commercial signal supports the squeeze. Spot-checking ACSP pricing pages over the past fortnight:

1. The cheapest mainstream offers sit around £15–£25 per individual, usually self-serve with document upload and an automated liveness check.
2. Mid-market accountants are pricing IDV at £35–£60 per person, often bundled into confirmation-statement work.
3. Premium agents serving overseas-incorporated groups are quoting £75–£120 per person, with white-glove handling and a 24-hour SLA.
4. A small number of ACSPs are now publishing "existing client only" notices, having paused new IDV-only mandates while they clear backlogs.

None of this is illegitimate price discovery — it is the predictable shape of a market with a hard regulatory deadline and uneven supply. But it does change the calculus for company secretaries who assumed their incumbent agent would simply absorb IDV inside an annual fee.

Early rejection patterns

We do not yet have official rejection statistics from Companies House — the first quarterly bulletin covering the mandatory regime is not due until July 2026. What is visible from agent forums, the One Login service status page and a small cluster of ICAEW practitioner notes:

• Name mismatches between the passport machine-readable zone and the existing CH record are the single largest cause of bounce-backs. Directors whose register entry uses a middle initial or anglicised forename are being asked to file an RP04 correction before IDV can complete.
• Older passports (issued pre-2017) are failing biometric checks at materially higher rates, pushing those users into the post-and-Post-Office fallback.
• PSCs who are corporate entities are causing confusion — the IDV requirement attaches to the relevant individual at the top of the chain, not to the corporate PSC itself, but the filing UI has been catching some agents out.
• Overseas directors without a UK address on the register are being routed straight to ACSPs, with no usable direct path.

If you advise clients, the practical implication is clear: pull the register entry first, reconcile the name and date of birth against the document the director will actually present, and file any CH01 / PSC04 corrections before booking the IDV slot. Trying to fix a name mismatch through One Login mid-flow does not work.

How the UK regime compares internationally

The UK is late to mandatory director identity. The two most useful comparators are Australia's Director Identification Number (DIN) and Ireland's CRO verification regime.

Australia's experience is the most instructive. The DIN rollout missed its original deadline, was extended by a year to December 2022, and even by mid-2024 ASIC was reporting roughly 10% of directors still unverified. Most of the long tail were inactive directors on dormant company boards who simply had no operational reason to engage. The UK regime is structurally similar — a hard deadline tied to a routine filing — and the same long tail is the obvious risk.

What existing directors should do this month

If you are an existing director or PSC, the trigger date that matters to you is the next confirmation statement filed by your company on or after 8 April 2026. Look up the made-up date on the public register; it is the day before the statement is due, and you must be verified by the day the CS01 is filed.

For most companies that means:

1. Pull a copy of every officer's register entry and reconcile names, dates of birth and service addresses against the documents they will present.
2. File any necessary CH01 (director details), PSC04 (PSC details) or RP04 (correction) before booking IDV.
3. Decide route: One Login for clean UK-resident cases, ACSP for everyone else. Get quotes now — pricing has hardened in the past fortnight.
4. Diary the IDV completion at least four weeks ahead of the confirmation statement due date. The fallback Post Office route adds a week even when it works first time.
5. For groups with overseas directors, do not wait for the next CS01 — the ACSP queue will only get worse through the summer as larger filers reach their renewal dates.

For accountants and company secretaries running portfolios, the more important diary entry is probably your busiest CS01 clusters. Many practices file a heavy concentration of confirmation statements in September–November to align with calendar-year accounts cycles. That cluster will hit the IDV market at the same time as the post-summer flow of new incorporations. Booking ACSP capacity, or registering as one yourself, is a Q2 task, not a Q3 one.

The bigger picture

IDV is the most operationally visible piece of ECCTA, but it is not the most consequential. The real shift is that Companies House now has both the legal power and the integrity-checking apparatus to reject filings, query directorships and remove names from the register without needing a court order. Identity verification is the data backbone that makes that possible.

Two weeks in, the regime is functioning — but the 12-month transition is going to be uneven. The companies that will struggle are not the bad actors the policy was designed to catch; they are the perfectly legitimate small and dormant companies whose registers have drifted out of alignment with reality, and whose directors have not logged into a government service in years. The fix for them is administrative, not regulatory, and it needs to happen well before their CS01 renews.