Identity verification is not an optional extra for company directors. It is a legal requirement with practical consequences if it is missed. The most important point is that this is not treated like a routine late filing fee. Companies House can take action against the company and against the people responsible, and an unverified director can also prevent the company from making a confirmation statement (Companies House non-compliance guidance; its identity-verification process guidance).
If you are searching for a “companies house ID verification penalty” or a “companies house identity verification fine”, the starting point is the published enforcement approach. It lists the available responses and confirms that an unverified director can be committing an offence (Companies House guidance). Put simply, the question “is not verifying identity a criminal offence?” has a different answer from an ordinary late-filing question.
This FAQ answers the penalty questions in plain English. It focuses on what the published enforcement approach says, rather than assuming that every late case will end in court (Companies House). If you need help completing verification before a filing becomes blocked, you can start an application with TAH. TAH is an Authorised Corporate Service Provider and can manage the verification route and Companies House submission for you.
The legal position for unverified directors
Is it actually a criminal offence not to verify my identity with Companies House?
Yes. It is unlawful for a director to act as a director without completing identity verification. Continuing to act while unverified can be an offence under section 167M of the Companies Act 2006; this is not simply a late-filing fee. The company may also be in breach if a director remains unverified (Companies House non-compliance guidance).
That distinction matters. A late filing fee is an administrative charge for missing a filing date. Here, the published position is that an unverified person should not continue to act as a director. The duty is not completed merely by starting an identity check: the published approach says that the person must complete identity verification to obtain a personal code and file a verification statement supplying that code (Companies House non-compliance guidance).
It is sensible to deal with the position promptly if verification has not been completed. That reduces the chance of a wider company filing problem and avoids leaving a director in a position that Companies House describes as unlawful. Our step-by-step guide explains the practical route from application to completion.
What Companies House can do
What specific penalties can Companies House impose?
Companies House can use a default letter, financial penalties at company and individual officer level, a public-register annotation, referral to The Insolvency Service, prosecution through the courts, director disqualification, fines and, ultimately, striking the company off the register. The action taken depends on the case (Companies House non-compliance guidance).
The toolkit is deliberately broad. A default letter can set out the offence and warn that further action may follow. Financial penalties may be aimed at the company or an individual officer. An annotation on the public register can show that the company is non-compliant. The more serious steps include a referral to The Insolvency Service, prosecution, a criminal conviction, disqualification and fines (the published enforcement approach).
These are possible responses, not a promised sequence in every case. That is why it is better not to treat an initial letter or a blocked filing as something that can safely be ignored. Resolve the verification requirement and make sure the required statement is filed.
Will an unverified director stop my company from filing its confirmation statement?
Yes. Companies House will not accept a confirmation statement while any director remains unverified. Since 18 November 2025, the filing is made with each director's personal code and verification statement, so one unverified director can hold up the company's filing (Companies House identity-verification process guidance).
This is often the immediate business problem. The confirmation statement belongs to the company, but it requires the relevant verification information for every director. One outstanding person can therefore stop the whole filing from being accepted. The fastest practical response is to identify every unverified director, complete verification, and then make the filing with the correct personal codes.
For directors who want assisted verification, TAH's ACSP service provides a managed route. TAH can carry out the identity check and submit the identity verification statement as authorised agent; Companies House sends the personal code directly to the applicant.
How enforcement is applied
Does Companies House prosecute every single late verification?
No. Companies House says it takes a fair and proportionate approach. It does not prosecute every late case, but its guidance says that three or more offences in a five-year period makes prosecution more likely. This is a guideline, not an automatic rule (Companies House; its non-compliance guidance).
“Fair and proportionate” should not be read as a reason to wait. It means Companies House looks at the circumstances and can choose a response from its toolkit. A default letter, a penalty or another step may come before prosecution, but the underlying duty still applies. The three-or-more-offences point is a guide for seriousness, not a threshold below which there can never be action.
If you are already late, focus on putting the position right rather than trying to predict the exact enforcement response. The practical objective is to stop the director remaining unverified and to remove any block on the company’s confirmation statement.
Get the verification process moving before an unverified director holds up your company filing.
Start your applicationExtenuating circumstances and the final risk
What if I have a genuine reason I couldn't verify on time?
You can raise genuine extenuating circumstances through a formal representation before the deadline. If Companies House accepts it, enforcement is typically paused for up to two months while the problem is resolved. The decision is final (Companies House non-compliance guidance).
A representation is for a real problem that prevented compliance, not a substitute for leaving verification until the last minute. It must be submitted before the relevant deadline. If accepted, the pause gives time to resolve the issue; it does not remove the need to complete the verification steps. Because the outcome is final, the representation should be accurate, focused and submitted in time.
Where the difficulty is simply that a director needs a supported verification route, act early. TAH offers an online/digital route and an in-person or manual route through its ACSP service. You can review the all-inclusive fixed fees before applying.
Can my company actually be struck off the register because of this?
Yes. Striking the company off the register is part of Companies House's enforcement toolkit. It is the ultimate step, rather than the only response to a missed verification, but it is available where the circumstances warrant it (Companies House non-compliance guidance).
It is not helpful to assume that striking off is either automatic or impossible. The published toolkit includes several possible measures, and Companies House says it will use a fair and proportionate approach. The sensible conclusion is that a company should not allow an unverified-director problem to continue simply because an early response appears less severe.
Complete both legal steps: verification to obtain the personal code, then the verification statement that supplies it. Keeping those steps separate in your checklist helps prevent the common mistake of assuming that an identity check alone has finished the job (Companies House published guidance).
Key takeaways
- Acting as an unverified director can be a criminal offence under section 167M; it is not just a late-filing charge (Companies House).
- Companies House can use letters, company and officer-level financial penalties, public-register annotation, referrals, prosecution, disqualification, fines and striking off (Companies House).
- One unverified director can stop the company’s confirmation statement from being accepted (Companies House).
- Companies House does not prosecute every late case, but three or more offences in five years makes prosecution more likely under its guideline (Companies House; its guidance).
- A genuine extenuating circumstance can be raised by a representation before the deadline; if accepted, enforcement is typically paused for up to two months (Companies House).