Skipping Companies House ID checks: fines and prosecutions

Key takeaways

The Insolvency Service secured the first convictions for Companies House identity verification offences at City of London Magistrates' Court on 16 September 2026.
The three directors were fined £80, £166 and £307, plus £85 costs each and a victim surcharge.
One director was convicted even though he had verified, because he did not take reasonable steps to stop an unverified co-director acting.
Under section 167M of the Companies Act 2006 it is an offence to act as a director unless your identity is verified, and the company and every officer in default can also be liable.
Companies House can issue a financial penalty of up to £10,000 instead of prosecuting, after a warning notice giving at least 28 days for representations.
Companies House treats non-compliance as likely to be serious where a person or company commits three or more offences in five years.
Other consequences include director disqualification, a note on the public register and being unable to be appointed to a new company.

Directors who skip Companies House identity verification can now be prosecuted, and three already have been. On 16 September 2026 the Insolvency Service secured the first convictions, with fines of £80 to £307 plus costs. Companies House can also impose financial penalties of up to £10,000 without going to court.

What happened in the first prosecutions?

Three directors were fined at City of London Magistrates’ Court on Wednesday 16 September 2026. The Insolvency Service and Companies House announced the cases in a press release on 17 September 2026.

Director and company	What they did	Fine
Jill White, White (Reading Properties) Limited	Acted and signed accounts while unverified	£166
Marc Dillon, White (Reading Properties) Limited	Failed to stop an unverified co-director acting	£307
Modinat Banjo, J Isogony Apparel Limited	Signed and delivered accounts while unverified	£80

Each director was also ordered to pay £85 in costs and a victim surcharge of between £32 and £123. All three were also convicted over their company’s confirmation statement: two for filing late and one for failing to file within the statutory period.

The Dillon case matters for every board. He had verified his own identity, but he knew the requirement and did not take reasonable steps to stop his co-director acting while unverified.

What offences can you commit?

The main offence is acting as a director without verifying. Section 167M of the Companies Act 2006, in force in full from 18 November 2025, says an individual must not act as a director unless their identity is verified.

The director commits an offence by acting while unverified.
The company must make sure no unverified individual acts as a director.
Every officer in default commits an offence if the company breaches that duty, which is how a verified co-director can be prosecuted.
PSCs may commit an offence if they do not verify by their deadline.

On summary conviction the penalty in England and Wales is a fine, with no maximum set in the section. In Scotland and Northern Ireland it is a fine up to level 5 on the standard scale, plus a daily default fine for continued contravention.

How Companies House financial penalties work

Companies House can impose a civil financial penalty instead of prosecuting. The power comes from section 1132A of the Companies Act 2006 and the Financial Penalty Regulations 2024 (SI 2024/445), in force from 2 May 2024.

Warning notice. Companies House sets out the grounds and gives at least 28 days, from the day after the notice date, for written representations.
Penalty notice. If still satisfied beyond reasonable doubt, it issues a notice with the amount, how it was worked out and how to pay.
Payment. You get at least 28 days to pay. Unpaid amounts carry interest.
Appeal. You can appeal to the County Court (England, Wales and Northern Ireland) or the Sheriff Court (Scotland) within 28 days, with permission.

The penalty cannot exceed £10,000, or the maximum fine a court could impose for the same offence if that is lower. Penalties can be a fixed amount, a daily rate, or both. You cannot be fined by Companies House and prosecuted for the same conduct.

Companies House has not published a tariff of standard amounts for identity verification penalties in the documents we checked.

How Companies House decides what to do

Companies House’s approach to non-compliance, last updated 5 December 2025, sets out a stepped approach: inform, nudge, deal with non-compliance, then tackle fraud.

Default letter. This sets out the offence and warns that enforcement may follow without further notice.
Three routes. Prosecution, referral to the Insolvency Service, or a financial penalty.
Seriousness. Three or more offences in five years is likely to be treated as serious, as a guideline.
Priority cases. Fake identity documents and criminal activity come first.
Representations. These must be in writing and on time. Companies House is likely to accept them only in exceptional circumstances, such as a serious IT failure, and then usually pauses enforcement for up to two months.

Other tools include director disqualification, annotating the register, court orders to file and striking companies off.

What else happens if you do not verify?

The consequences go beyond a fine. Companies House says that if you do not verify:

the company cannot file its confirmation statement until every director has verified
a note may be published against your name on the public register
you cannot be appointed as a new director of an existing company
you cannot register a new company or register as an ACSP

Companies House’s business plan for 2026 to 2027, published 19 May 2026, commits to “proportionate action against those who fail to verify their identity”. The 12-month transition for existing directors and PSCs ends in mid-November 2026.

What directors and advisers should do now

Verify today if you have not. See how to verify your identity.
Check every co-director. The Dillon case shows a verified director can still be liable.
Stop unverified directors acting. They should not sign accounts or take board decisions until verified.
Check PSC windows. See PSC identity verification.
Reply to any warning notice within the 28 days.

Our November 2026 deadline guide and directors’ responsibilities cover the wider duties.

Frequently asked questions

Can I be prosecuted for not verifying my identity with Companies House?

Yes. Acting as a director without verifying is an offence under section 167M of the Companies Act 2006, and three directors were convicted on 16 September 2026.

What is the maximum Companies House penalty for not verifying?

A Companies House financial penalty cannot exceed £10,000, or the court maximum for the offence if lower. A court can impose a fine instead.

Can I be prosecuted if I verified but my co-director did not?

Yes. The company must ensure unverified people do not act as directors, and every officer in default can commit an offence. One director convicted in September 2026 had verified.

Will I get a warning before a Companies House penalty?

Yes. Under the 2024 regulations, a penalty notice can only follow a warning notice that gives at least 28 days for written representations.

Can I be fined by Companies House and prosecuted for the same thing?

No. The regulations bar a penalty if you are being prosecuted or have been convicted for the conduct, and bar prosecution once a penalty has been imposed.

Sources

Rates, thresholds and rules in this guide were checked against HMRC and GOV.UK guidance on 6 November 2026. Tax rules change, so check the current position on GOV.UK or with a qualified adviser before acting. This guide is general information, not personal advice.