Pension Scheme Trustee Directors – Identity Verification Requirements

On 18 November 2025, a requirement will come into force for individual directors of UK companies to verify their identity. This requirement will apply to individual directors of all UK companies – including directors of a company which has been appointed as the trustee of an occupational pension scheme (referred to in this update as “trustee directors” of a “trustee company”).

What are the identity verification requirements?

Under the Economic Crime and Corporate Transparency Act 2023 (the “Act”), individuals will be prohibited from acting as a company director unless their identity has been verified and companies will be under an obligation to ensure that individuals do not act as a director unless their identity has been verified. A director’s appointment must also be notified to Companies House within 14 days and, if notice is not given within that period, the director will be prohibited from continuing to act as a director until notice has been given. Breach of these requirements will be a criminal offence punishable by a fine, with the offence being committed by the director concerned, as well as the company and its other directors.

Individuals will be able to verify their identity in two ways:

• Directly with Companies House using GOV.UK One Login.
• Using an “authorised corporate services provider”.

Companies House has issued guidance for individuals on verifying their identity.

Once an individual has successfully verified their identity, they will receive a unique identifier known as a Companies House personal code. This code is personal to the individual, rather than belonging to their company or employer, which means that the individual will not be required to verify their identity again. The individual’s personal code must be used in all filings and formal communications concerning that individual with Companies House. Individuals should only share their personal code with Companies House and any person authorised to make filings at Companies House on their behalf.

What does this mean for trustee directors and trustee companies?

From 18 November 2025:

• All new trustee directors will be required to verify their identity before being appointed (unless they have previously verified their identity and already have a Companies House personal code). The new trustee director’s personal code will need to be included in their appointment filing, and that filing must be submitted to Companies House within 14 days of the trustee director’s appointment.
• All existing trustee directors will be required to verify their identity before the trustee company submits its next annual confirmation statement. The deadline for completing identity verification for existing trustee directors will therefore depend on when the trustee company’s annual confirmation statement is next due. The trustee directors’ Companies House personal codes will need to be included in the confirmation statement.

Although the requirement for identity verification does not come into force until 18 November 2025, individual trustee directors can choose to verify their identity ahead of that date if they wish.

Is anything else changing from 18 November 2025?

The Act also requires persons with significant control of a UK company to verify their identity. In addition, the Act makes changes to the records that UK companies are required to maintain and to the information that UK companies are required to file at Companies House. These changes will likewise come into force on 18 November 2025.

What should trustee directors be doing?

You should speak with the company secretarial services provider for the trustee company (or whoever normally carries out Companies House filings for the trustee company) to confirm that they are aware of the changes and that steps will be taken to ensure compliance with the new requirements by the trustee company and its trustee directors.

You should also ensure that the identity verification and Companies House notification requirements for the appointment of new trustee directors are complied with from 18 November 2025.