First directors convicted for not verifying their identity: what the 16 September 2026 cases mean for you

On 16 September 2026, three directors became the first people convicted for Companies House identity verification offences, at City of London Magistrates' Court, after prosecutions brought by the Insolvency Service. Two had acted as directors without verifying their identity. The third had verified, and was convicted for failing to take reasonable steps to stop a co-director acting while unverified. The fines were £80, £166 and £307, each with £85 costs and a victim surcharge of between £32 and £123. The Insolvency Service's line was short: "There is no option to opt out." The amounts are small. The criminal record is not, and the co-director conviction means an unverified colleague is now every board member's problem.

What happened in court

The Insolvency Service and Companies House published the details on 17 September 2026. The cases involved two companies.

At the first company, one director took part in board-level decisions and signed company accounts while unverified. She completed identity verification in early September 2026, around nine months after her deadline and shortly before the hearing. She was fined £166, with £85 costs and a £66 victim surcharge.

Her co-director had verified his own identity. He was prosecuted because, knowing the legal requirement, he did not take reasonable steps to prevent her continuing to act as a director while unverified. He was fined £307, with £85 costs and a £123 victim surcharge.

At the second company, the sole director signed and delivered accounts while unverified. She completed verification on or around 28 May 2026. She was fined £80, with £85 costs and a £32 victim surcharge.

All three were also convicted after their companies failed to file a confirmation statement on time. That is no coincidence: the statement is where a director's personal code is provided, and Companies House says it cannot be filed until every director has verified. One unverified director leaves the company late, and both failures end up on the charge sheet.

The Insolvency Service said that in both cases "multiple opportunities were provided for the directors to comply with the requirements before enforcement action was taken."

The co-director conviction

This is the part most directors have missed. Verifying yourself does not close the risk if someone else on the board has not.

GOV.UK's guidance says: "If you continue to act as a director after the deadline without complying with all verification requirements, you will be committing an offence. The company (or entity) and all directors may also be committing an offence." Companies House's published enforcement approach adds that if an individual breaches the requirement, the whole company is also in breach, and that it may issue financial penalties "at company or individual officer level".

The Insolvency Service's lawyer put it this way: "These prosecutions demonstrate that directors have responsibilities not only for their own compliance but also for ensuring unverified individuals do not continue acting as directors on behalf of a company."

In practice that means a verified director who knows a colleague has not verified needs to do something about it: raise it in writing, chase it, and if it goes nowhere, consider whether that person should keep acting. "I did mine" was not a defence on 16 September.

What the Insolvency Service and Companies House said

Daniel Hart, Senior Criminal Lawyer at the Insolvency Service: "There is no option to opt out. Directors who continue to act without verifying their identity risk investigation and prosecution."

Martin Swain, Director of Intelligence and Law Enforcement Engagement at Companies House: "These cases send a clear message that identity verification is not optional. The vast majority of directors and people with significant control will comply with the new requirements, but where individuals fail to meet their legal obligations, Companies House will take appropriate enforcement action."

Companies House's enforcement approach describes a ladder: emails and letters first, then a default letter when a date is missed, then financial penalties, referral to the Insolvency Service, or prosecution. It treats three or more offences in five years as a guide to what counts as serious. These three cases show the ladder is being climbed.

Why a small fine is not the point

A conviction at a magistrates' court is a criminal conviction, whatever the fine. Under the Rehabilitation of Offenders Act 1974 a fine becomes spent after one year. Until then it is an unspent conviction: it must be declared when an application asks about unspent convictions, and it appears on a basic DBS check.

For a company director that is wider than it sounds. Proposal forms for directors' and officers' insurance, professional indemnity and some commercial policies ask about convictions. Professional bodies and regulators expect members and approved persons to tell them. Some visa and residency applications ask about any conviction, not only unspent ones. A regulated firm's "fit and proper" assessment can ask the question with no time limit at all.

There is also the public record. The Insolvency Service published the directors' names, ages, home towns and companies on GOV.UK, and the trade press repeated them. For someone who raises money, tenders for contracts or sits on other boards, an online search now returns a conviction for ignoring a legal requirement that takes ten minutes to meet.

And the fines are not the only money. Each defendant paid £85 costs and a victim surcharge, roughly doubling the smallest penalty. A civil financial penalty from Companies House, where it chooses that route instead, has no published tariff.

Where the numbers stand

Companies House's official statistics for April to June 2026 showed 55% of director appointments and 42% of individual PSC appointments verified at 30 June 2026. The transition year for existing directors and PSCs ends on 18 November 2026, and Companies House has estimated that 6 to 7 million people need to verify by then.

The people prosecuted so far were months past their dates and had ignored repeated contact. That is the group the Insolvency Service has started with.

What to do now

1. Check who at your company must verify and who has. The public register shows, for each director and PSC, whether the verification statement has been supplied and the date Companies House wants it by. Our free checker at https://guides.vaulex.co.uk/am-i-affected reads it live.
2. Verify yourself if you have no personal code. GOV.UK One Login is free: the app reads the chip in a biometric passport with an NFC-capable phone and runs a face match. It cannot always be used from abroad, and there is no manual route at Companies House.
3. If One Login stops, use an Authorised Corporate Service Provider (ACSP), an agent registered with Companies House and supervised for anti-money laundering. The ACSP checks your passport and proof of address, tells Companies House, and Companies House emails your 11-character personal code.
4. Provide the code for every role at every company: in the confirmation statement as a director, and through the PSC service as a PSC, within the 14-day window.
5. If a co-director has not verified, put it in writing today. The conviction on 16 September was for knowing and doing nothing.

Vaulex Group is an ACSP (AP021384). An AML-qualified person reviews every case, including the ones the app turns away. Standard verification is £149.99 per person, three working days from when everything is in. Fast track is £349 per person: your code within 24 hours counted on working days, once you have completed the biometric checks and we have everything we need.

This is information, not legal advice; we are not solicitors or accountants. If you have received a summons or a letter threatening prosecution, speak to a solicitor.

Start when you are ready

Order verification at https://my.vaulex.co.uk/verify, or check your company first at https://guides.vaulex.co.uk/am-i-affected. Do it before the next letter arrives.