Directors fined in first Companies House identity verification prosecutions

The first court cases under the new identity verification regime are a clear warning that directors must comply with their Companies House obligations before the applicable deadline. Late completion of identity verification may not prevent enforcement action.

First convictions secured

On 16 September 2026, the Insolvency Service secured the first convictions for offences connected with Companies House identity verification. Jill White and Marc Dillon, directors of White (Reading Properties) Limited, and Modinat Banjo, director of J Isogony Apparel Limited, were fined at City of London Magistrates’ Court.

White continued to take part in board-level decisions and signed company accounts, while unverified. Dillon had verified his own identity but was prosecuted for failing to take reasonable steps to prevent an unverified co-director from continuing to act. Banjo also continued acting and signed and delivered company accounts before completing verification.

The fines were £166 for White, £307 for Dillon and £80 for Banjo. Each was also ordered to pay £85 in costs and a victim surcharge. The convictions included related failures to file confirmation statements on time, so the figures should not be treated as a fixed tariff for identity verification breaches. The official Insolvency Service and Companies House announcement makes clear that directors who continue to act without verification risk investigation and prosecution.

What the law requires

Identity verification became a legal requirement on 18 November 2025 under reforms introduced by the Economic Crime and Corporate Transparency Act 2023. A newly appointed director must verify their identity before acting. Existing directors must verify during the 12-month transition period and provide their personal code when the company files its next confirmation statement.

Section 167M of the Companies Act 2006 prohibits an individual from acting as a director unless their identity is verified. It also requires the company to ensure that an unverified individual does not act. This means that compliance is not merely personal: directors and other officers must consider whether every director on the board has completed the required process.

Non-compliance can lead to a financial penalty, prosecution and restrictions on company filings or forming a new company. Companies House may first inform, remind and guide those affected, but its published approach to any non-compliance confirms that persistent breaches can move into formal enforcement.

Practical steps for companies and directors

• Check the Companies House register for the verification due date attached to each director role
• Verify directly through GOV.UK One Login or through an Authorised Corporate Service Provider
• Keep the Companies House personal code secure and provide it to the person filing the company’s confirmation statement
• Confirm that every director—not only the person responsible for filings has completed verification before continuing to act
• Record completion and diarise the company’s confirmation statement deadline.

Why this matters

These cases show that late verification does not necessarily erase an earlier offence and that a director who has personally complied may still face consequences if an unverified co-director is allowed to continue acting. Companies should therefore treat identity verification as an active governance obligation rather than a routine administrative task.

Higgs can help

Higgs can guide directors through the Companies House identity verification process, help identify and monitor relevant deadlines, and support companies with submitting the required personal codes. Our team can also review, establish and maintain statutory registers, ensure changes to directors, shareholders and people with significant control are recorded promptly, and assist with related Companies House filings so that corporate records remain accurate and up to date.