Tuesday 08-04-2025 - 16:27

A new duty for company directors to verify their identity is being rolled out over the next year. This will impact all SUs who are incorporated as a company limited by guarantee (CLG) because trustees are also company directors. 

The changes will be phased between Spring 2025 and Autumn 2026. At this stage, the advice from NUS Charity is that SUs understand the new requirements and start considering how to implement in 2026. 

Summary of changes 

• All company directors will be required to verify their ID. As well as directors, Persons of Significant Control (PSCs) and anyone who files for a company will need to verify their ID. 
• Directors will not be able to act until their ID is verified. This is a change from the current situation, where a director needs registering at Companies House but can act as a director whilst this is processing. 
• Directors will need to do this themselves online using the GOV.UK One Login 
• An alternative option is to use an Authorised Corporate Services Provider (ACSP) to perform the checks. This could include solicitors, accountants or governance professionals. Importantly, we don’t believe this can be done in house (as you would with DBS or right to work checks). 
• A director only needs to do this once. In theory once verified with Companies House they wouldn’t need to do again for a new directorship. 
• At the time of writing (Spring 2025) the checks are voluntary, but from Autumn 2025 onwards they will become mandatory. 
• From Autumn 2025 all new directors will need to verify their ID. 
• This will also apply to existing directors. From Autumn 2025 they will need to verify their ID but there will be a 12 month grace period. 

Read about director ID. 

This forms part of wider reforms to Companies House as part of the Economic Crime and Transparency Act. Find out more about the changes. 

Impact on SUs

This only impacts SUs who are registered companies. 

The nature of our movement is that there is a high turnover of trustees. New officers and student trustees are elected each year. Students tend to be elected for one year and of course the Education Act limits officer terms to two years. This means onboarding new directors happens every summer. We have a lot of first-time trustees so this will clearly be a process we’ll have to do regularly. 

On the timelines above there is no immediate action for your incoming (July 2025) officers, student trustees and externals that you are in the process of recruiting. By the autumn they will be existing directors and there will be a further year to verify, by which point many will have finished their term. 

For recruitments to the trustee board from autumn onwards you’ll need to factor in director ID. 

We strongly recommend you are prepared for this. Directors will not be able to act until their ID is verified meaning there could be issues with decision making and quorum. This is why it is vital to plan, and from the autumn to start the ID verification process with existing trustees. 

NUS Charity will continue to update on this. We’re planning to run through the ID verification process to feed back how easy it is plus update on any other info after this goes live. 

If you have any questions or would like to discuss, get in touch with Richard Whitmill.