Board Minutes to Document and Approve IDV of Existing Directors 
In accordance with section 167M(2) of the Companies Act 2006 (introduced by the Economic Crime & Corporate Transparency Act 2023 (ECCTA)), a company will commit an offence if it allows a person who has not verified their identity, to act as a director. From 18th November 2025, UK company directors must verify their identity. There are different rules in place for new and existing directors. For existing company directors, there is a 12-month transition period for compliance, tied to the timing of a company’s annual confirmation statement. This means that the amount of time existing directors have to verify their identity will vary significantly depending on the date that their confirmation statement is due. Companies House is encouraging all directors to verify their identity as soon as possible to avoid any delays.
Whilst the process of identity verification (IDV) falls to each individual director to fulfil, given the section 167M(2) obligation on a company, it is useful for a company to have documentary proof that it has approved and highlighted the need for all directors to verify their identity. These template board minutes can be used for this purpose.
These board minutes note that the IDV regime has come into force, the timing of IDV for existing directors, the methods by which a director may IDV, the unique identification code that will be issued to each director once they have successfully verified their identity, confirmation that the directors are not disqualified under the update directors’ disqualification regime and confirmation that the company has communicated with its directors in relation to the IDV regime.
The timing of IDV for new directors is different and must be done before their appointment. See here for more details.
The ECCTA gives Companies House new and enhanced powers to help disrupt economic crime and the IDV regime is a key component of this.
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