Directors fined as Companies House ID checks get their first prosecutions

Three company directors have been fined in the first prosecutions for Companies House identity verification failures under the Economic Crime and Corporate Transparency Act 2023, the Insolvency Service and Companies House said in a joint announcement on September 17, 2026.

All three appeared at City of London Magistrates’ Court on September 16. Jill White and Marc Dillon, both directors of White (Reading Properties) Limited, and Modinat Banjo, sole director of J Isogony Apparel Limited, were each also convicted over a late confirmation statement.

The underlying rule is not new. Newly appointed directors have had to verify their identity before acting since November 18, 2025, while existing directors fall due during a 12-month transition period, tied to the company’s next confirmation statement rather than to one fixed date.

“There is no option to opt out,” said Daniel Hart, senior criminal lawyer at the Insolvency Service. “Directors who continue to act without verifying their identity risk investigation and prosecution.”

Three convictions, three different failures

White, 62, of Speen, Buckinghamshire, acted as a director while unverified, participating in board-level decision making and signing company accounts, according to the announcement. She completed verification in early September 2026, days before the hearing.

Banjo, 50, of London, signed and delivered accounts on behalf of J Isogony Apparel Limited while unverified. She completed the process on May 28, 2026, before the case reached court.

Dillon, also 62, of Benson, Oxfordshire, had verified his own identity. He was prosecuted for failing to take reasonable steps to prevent White from continuing to act as a director while unverified.

That third charge is the one most likely to catch firms out. Verifying yourself does not discharge the duty to stop a co-director acting unverified.

Hart said the cases “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.” The announcement does not set out what reasonable steps amount to, which leaves that standard to be worked out case by case.

Every one of the three convictions paired the verification offence with a late confirmation statement. For practice managers triaging a client book, the overdue filing is the symptom that surfaces first.

Companies House identity verification fines stay small

White was fined £166 with £85 costs and a £66 victim surcharge. Dillon received a £307 fine, £85 costs and a £123 surcharge. Banjo was fined £80, with £85 costs and a £32 surcharge.

Those sums sit well below the cost of a criminal conviction attaching to a serving director. Whether they deter anyone weighing the administrative effort of verification against the odds of enforcement is a separate question, and one the announcement does not address.

Hart said multiple opportunities to comply were provided before enforcement action was taken. That framing points to persistent non-compliance, rather than administrative slippage, as the current trigger for prosecution.

Martin Swain, director of intelligence and law enforcement engagement at Companies House, called the prosecutions “an important milestone in strengthening the integrity of the UK’s company register.”

The milestone is a small one measured against the workload. Companies House has estimated that 6 million to 7 million individuals need to verify by mid-November 2026, when the transition period closes.

Three prosecutions against a population that size tell firms little about how aggressively the rule will be policed once the deadline passes. They do establish that the offence is chargeable, which is a different and more useful point.

What Companies House identity verification means for accountants

For firms acting as agents the task is administrative rather than technical. Verification through GOV.UK One Login is free, or it can be done through an Authorised Corporate Service Provider, a route many practices already operate and price themselves. Checks run by an ACSP must meet the same standard of assurance as verification completed directly with Companies House.

The requirement also covers people with significant control, not only directors. A client’s verification list and its board list are not the same document, and structures with corporate or family shareholdings will produce names that never appear in board minutes.

New appointments cannot lawfully begin without verification. Existing directors run on a clock set by each client’s own confirmation statement date, so a single internal cut-off applied across a client book will miss cases.

That makes the confirmation statement schedule the working document, not the November deadline. A client filing in October is already out of time in a way that a client filing next spring is not, and only the filing calendar shows which is which.

The Dillon conviction widens the exposure further. Practices advising multi-director boards need every director verified, not only the partner’s usual contact, and an unverified co-director is now a live risk to the verified ones.

Companies House has published guidance on verification and the wider Act, and the Insolvency Service operates a Director Information Hub covering director duties more broadly. Once the transition period closes in mid-November 2026, the deadline stops being a moving target, and a client’s confirmation statement date is no longer available as an explanation.