Impact assessment

Companies House: equality impact assessment for identity verification

Published 28 May 2026

Part A - Initial screening questionnaire

Name of person completing the template	Andrew Williams
Role of person completing the template	Identity verification lead
Date completed	30 April 2026

Policy or process information

Name of policy or process	Identity verification
Purpose and intended aim of the policy or process	Identity verification is a core part of the Economic Crime and Corporate Transparency Act 2023. It sits alongside other projects to implement legislative reforms. The objective of identity verification is to ensure that a relevant individual is who they say they are, and in turn to provide greater certainty over the identity of those shown as setting up, owning, managing or controlling companies in the UK.
Who is the policy or process intended for?	Internal and external stakeholders
Status of the policy or process?	Existing policy or process
Date policy or process was last reviewed (if relevant)	30 April 2026

Analysis

Does the policy or process have the potential to affect any of the groups listed below negatively?

Age	Yes
Disability	Yes
Sex	No
Gender reassignment	Yes
Race	Yes
Religion or belief	Yes
Sexual orientation	No
Marriage or civil partnership	Yes
Pregnancy and maternity	No

Decision making

If you have answered yes, or unsure to any of the questions above you are now required to complete a full equality impact assessment (EQIA)
No further action	Not applicable
Proceed to full EQIA	Yes

Signatory	Not applicable - Full EQIA required
Job title	Not applicable
Date	Not applicable

Part B - Full EQIA template

Part 1 - Outline your proposal

Identity verification is a core part of the Economic Crime and Corporate Transparency Act 2023 (ECCTA). From 18 November 2025 ECCTA requires the Registrar of Companies to verify the identity of directors, people with significant control (PSCs), and equivalent officers for other entities in scope. This includes verifying the identity of those already on the Companies House register, as well as those transacting (within scope of the legislation) with us (Companies House) for the first time. This includes incorporations. The need to have a verified identity will also apply to those presenting information on behalf of a company (to be implemented as a later phase). Identity verification improves the integrity and reliability of information contained on the public registers, driving trust and confidence.

Companies House has developed the appropriate systems and processes, enabling the verification of identities. There are no notable exemptions to the legal requirement for directors and PSCs other than for national security reasons. The policy is aimed at ensuring people are who they say they are. It is understood that not everyone will be able to verify their identity to the required standard. This is essential to preventing bad actors, who wish to utilise the register to commit economic crime, from completing verification. However, all those in scope of requirements must have a reasonable opportunity to attempt to verify.

While independent, the Companies House identity verification standard is based upon a medium level of assurance profile within the Government Digital Services Good Practice Guide 45 (GPG45) identity proving framework. Aligning to this level of assurance allows Companies House to achieve a robust confidence in the individual’s claimed identity. It also aligns to other identity verification standards and profiles used across UK Government. Companies House have tailored the standard to meet our specific requirements and customer needs where appropriate.

Companies House data is used in millions of financial, investment and business decisions annually. Accordingly, it is essential that the public have confidence in the accuracy and integrity of that information and reinforces the need for the identity verification standard.

The way the Registrar verifies identities to the required standard is determined by several factors. The vast majority of users will be able to verify their identity using GOV.UK One Login at no cost. There are 3 primary ways to prove your identity with One Login:

• with the GOV.UK One Login app
• online (computer or laptop) including the answering of knowledge-based questions
• at a Post Office

A small proportion of the Companies House register (-2%) may not be able to use One Login because their jurisdiction does not offer biometric identity documents to its citizens. One Login primarily requires that non-UK residents use biometric passports to complete verification to maintain the robustness of their checks. Additionally, individuals from those jurisdictions may not be able to answer dynamic security questions and/or access a UK Post Office. This cohort of individuals will be processed via an alternative software package, in conjunction with a team of specialist document examiners within Companies House. This enables verification to be attempted using a wider set of identity documents, including passports and National ID cards.

Companies House has also embedded support where, in exceptional cases related to disability as defined by the Equality Act 2010 (and potentially other intersectional factors, such as age), individuals should be referred to an in-house team who are trained in scrutinising and processing identity documents. This will only be considered once individuals have been given detailed guidance and support to complete verification via the One Login journey (if appropriate). Collectively, the above channels are referred to as the ‘Registrar’s verification routes’.

Individuals may alternatively choose to pay for Authorised Corporate Service Providers (ACSPs) to verify their identity. ACSPs must also apply the same standard as the Registrar as set out in Registrar’s Rules. ACSPs are individuals or organisations that undertake anti-money laundering (AML) supervised activity, such as company formation agents, solicitors, accountants, chartered secretaries and governance professionals. As these services are entirely separate to the Registrar’s verification route, this assessment does not consider any Equality Act 2010 implications for verification via ACSPs.

Part 2 - Summary of the evidence considered in demonstrating due regard to the equality duty

The focus/scope of this EQIA is the suitability of the identity verification service and the Registrar’s verification routes and not identity verification policy.

Companies House, GOV.UK One Login and the Department for Business and Trade evidence

There are many legal responsibilities that apply to directors and PSCs. This assessment considers the identity verification service through the lens of people who are acting in a professional capacity. This is in line with the Department for Business and Trade (DBT) analysis for the ECCTA Equality Impact Assessment which concluded that: we do not have any evidence to suggest that individuals in the most affected professional capacities (such as company directors) are disproportionality likely to fall under the protected characteristics. We thus do not foresee any clear negative impacts on the individual level, and especially no reason to expect any disproportionate negative impact on those protected by the Equality Act 2010.

Companies House introduced the One Login service approximately 6 months ahead of the intended legal commencement of the ECCTA requirements for directors and PSCs. This was to allow company directors and PSCs time to prepare. This voluntary period provided valuable feedback from users and additional insight into the process as a whole. At the time of this review over 4 million people have successfully verified their identity (receiving a personal code), with over 800,000 verified via ACSPs. Success rates on One Login are currently averaging 75%. There is no data available on ACSPs success rates. Using this insight we have updated this impact assessment and considered all protected characteristics in relation to the Registrar’s verification routes.

We also used the following evidence to understand potential impacts.

One Login’s 2023 user segmentation survey, A4 - WIP GOV.UK One Login user segmentation survey: Summary, showed:

• 92% of respondents have photo ID sufficient for medium confidence
• 92% of respondents could prove their identity in person at a Post Office

As a result of the survey GDS identified a number of areas where there was an opportunity to design ways to help more people use their service:

• address the digitally excluded
• remove authentication barriers
• remove barriers to using the app
• remove barriers to authenticating at a Post Office
• remove barriers to answering knowledge-based verification (KBV) questions
• allow users to get support and information from people they know and trust
• support minors (13 to 17 years old)
• improve accessibility of GOV.UK One Login

Since the survey GDS has widened the evidence types and government data sources for users they know will find it particularly difficult to prove their identity online which they say will significantly support addressing these barriers. More commentary is included in this blog, GOV.UK One Login: Designing for inclusion at scale – Government Digital Service.

Other available evidence which is not specific to the identity service

Companies House considered the Elections Bill equality assessment for comparison purposes. The Cabinet Office commissioned a nationally representative survey of eligible voters in Great Britain in 2021, providing evidence on the possession of the full range of photographic identification planned to be accepted for the policy. Overall, 98% of those surveyed had at least one form of photographic identification and 94% said they felt/believed it would make it easier or have no impact on their ability to vote. Whilst the percentage of the electorate who do not currently own identification is small (2%), of the 2% it is not possible to determine how many would be directors, PSCs or other individuals required to complete identity verification.

A 2021 Photographic ID Research study found:

• older people slightly less likely to hold photo ID than younger people - those aged 50 to 69 (3%) were one percentage point more likely (than average) to own no photographic ID
• white individuals less likely to hold photo ID than those from ethnic minorities
• those with disabilities less likely to hold photo ID than those without

In relation to each protected characteristic, we also considered the following evidence:

Age

During the voluntary period we received customer contact citing age as a prohibitive barrier to using the One Login service. However, many cases conflate age and lack of capacity, or age and digital exclusion. The Companies Act 2006 states that directors must be at least 16 years old but there is no upper age restriction. There are no age restrictions for PSCs meaning minors are in scope of the requirement. There were zero complaints related to PSC minors. Analysis of the registers shows the breakdown of directors by age group. A snapshot of the register from 24 October 2024, shows there were over 878,000 officer appointments over the age of 65, however there is no assessment of the accuracy of that data.

There is evidence to say that older people may have poorer digital skills. The most recent ONS study in 2021 showed only 54% of adults aged 75 years and over in the UK are regular internet users. Age UK research shows that around half (49%) of people aged 75 and over in the UK in 2023, around 3 in 10 (29%) aged 65 to 74, and around 1 in 7 (16%) aged 55 to 64 are unable to complete all 8 of the tasks required to set someone up for success online.

Disability

During the voluntary period we received customer contact citing accessibility as a barrier to using the One Login service. Blind or partially sighted users were of note in those cases. Some of those cases also included directors with indicators of functional impairments and/or impaired decision-making capacity, as evidenced by Powers of Attorneys for example.

We know from generic equalities data that people with disabilities (specific impairments) have greater challenges in accessing digital services. As the latest estimates from the Department for Work and Pensions’ Family Resources Survey indicated, 24% of the total UK population had a disability in the financial year 2021 to 2022. 

Race

We identified no specific evidence about race. However, a potential indirect impact as a result of nationality or country of residence was identified as a possible barrier to using the One Login service. One Login coverage is significant, however, as of May 2025 it was estimated that 117,639 individuals already on the register (nationals of 112 countries and residing overseas), would be outside of One Login coverage. These 112 countries do not issue identity documents (such as ‘chipped/biometric’ passports) which can currently be accepted through the One Login service. 

Sex

There was no customer contact during the voluntary period relating to sex. The legal requirement applies equally to all sexes. There is no definitive data on the split between men and women on the registers as sex is not reported.

Gender reassignment

There was no customer contact during the voluntary period relating to gender reassignment. There is no available data on directors or PSCs who have had gender reassignment.  

Religion or belief

There was no customer contact during the voluntary period relating to religion or belief. We are aware that some religious groups prohibit or limit the use of technology, although there is limited data available on this, and as such they may not be able to use the existing or enhanced digital service for identity verification. There is no available data on directors’ or PSCs’ religion or belief.  

Sexual orientation

There was no customer contact during the voluntary period relating to sexual orientation. There is no available data on directors’ or PSCs’ sexual orientation.  

Marriage or civil partnership

There was no customer contact during the voluntary period relating to marriage or civil partnership. However, as part of process design, a potential impact was identified if a person is wrongly flagged for further checks where their name used in the identity check does not match the name on the register because of marriage or civil partnership. There is no consistent data on directors’ or PSCs’ marital or relationship status. Some people choose to include Mr or Mrs for example in titles but this is optional and therefore not authoritative.  

Pregnancy and maternity

There was no customer contact during the voluntary period relating to pregnancy or maternity. There is no available data on directors’ or PSCs’ pregnancy or maternity.

Part 3 - Identify the impacts

The Registrar must be able to show that any disadvantage due to the noted characteristic is a proportionate means of achieving a legitimate aim, meaning compliance with identity verification duties. Practically, the requirement is to, as far as possible, remove disadvantage and create a level of parity between those with and without protected characteristics.

The 2 most notable protected characteristics that may impact upon an individual’s ability to attempt to complete the identity verification check are:

Age

Due to levels of digital confidence, lack of technology or devices and the absence of family, friends, or community-based support. This characteristic may also influence the types of documents an individual holds or is able to obtain.

Disability

Functional or physical impairment could limit the document types available and prohibit an individual’s ability to undertake the identity verification process, for example, they may be unable to use devices and/or are unable to be supported through the journey by a trusted individual. Individuals can be supported through the One Login journey by family, friends or trusted others. This includes use of another person’s device. Companies House will also provide additional guidance and support including where charities such as Ability Net may offer additional services. In some cases, the disability may impact a director’s capacity to act. A company’s articles of association will almost always provide for a director’s appointment to be terminated if they lack capacity. This is a matter of internal governance for the company and its other directors/members in each case, for example, will they permit the director’s properly appointed attorney/agent to act on their behalf. In these cases, Companies House will sensitively help users consider any appropriate options.

There are potential indirect impacts to race and nationality for users using the One Login service due to the identity documents that may or may not be available in particular jurisdictions.

There are potential indirect impacts to religion or belief. The identity verification process includes digital elements, such as a (mandatory) email address and a smart phone or similar internet connected device. Individuals needing to go through the process who object to the use of technology will need to consider acquiring assistance from a trusted person or charity to support them with the journey.  

There are potential indirect impacts to individuals on the registers that change their name due to marriage or civil partnership especially where the name on the register is different to the name on their identity documents. As part of the identity verification process, we will ask because an individual is using a name other than the one used to verify. This is necessary to confirm it is the correct person however if the response is not satisfactory, we may require additional evidence.

There are potential indirect impacts to individuals that identify as a different gender than the gender they were assigned at birth (gender reassignment). There is a possibility that an individual who has undertaken gender reassignment may have a different appearance if they have not updated their photo ID. In this instance Companies House may require the individual to update their photographic ID depicting their current appearance to enable identity verification or they could use the knowledge-based verification route within the One Login service.

There is no identified impact in relation to sex, sexual orientation or pregnancy and maternity and no data to indicate otherwise.

Part 4 - Analyse the impacts

To mitigate risks around age or disability, there is additional guidance and support to anyone who needs help using GOV.UK One Login. Users can contact the GOV.UK One Login team to get help, report a problem or give feedback. They can also ask someone they know and trust to help them if they do not feel comfortable using One Login independently. More guidance is available at Find out what the person you ask can and cannot help you with.  To understand the impacts on different individuals, user testing has been carried out by Companies House and One Login. A typical verification journey involves a user starting off at Companies House, then completing their ID check via the One Login service. Upon the successful completion of this check, they are returned to Companies House services to receive their personal code, and to then conduct necessary filings, such as filing the confirmation statement, and/or the PSC verification statement.

Companies House has also undertaken several rounds of accessibility testing with users with accessibility needs on their parts of the identity verification journey:

• 12 user interviews with users trying to verify their identity with Companies House
• 6 user interviews with users trying to register/sign in to Companies House using the One Login based solution (IDAM)
• 15 interviews with users with accessibility needs testing the PSC journeys – verify and link your identity - some of these users were also directors
• accessibility research conducted with ACSPs
• 8 rounds of research have also been completed with participants in Pakistan, India, and South Africa

One Login supports accessibility in a range of ways:

• they have undertaken over 100 rounds of user research with 1 in 4 participants that are disabled
• they also performed specific testing rounds with users of assistive technology, and are planning to do this regularly for all the parts of their user journey - the findings from this research inform the design decisions of the system - capturing the experience of participants with a spectrum of disabilities helps to ensure their solution works for as many people as possible
• since January they have had 30 different accessibility checks and continue to work to improve the products further including how long it takes to react to fixing an issue
• One Login’s accessibility team runs both manual and automated accessibility testing of the journey, which includes assistive technology testing - each new feature or change is audited for accessibility issues - their accessibility statement is up to date
• they state One Login uses knowledge-based verification (KBV) questions as an alternative identity check for users who cannot or choose not to use the One Login Identity Document (ID) checking app - as KBV questions require users to correctly answer a series of questions, it can present challenges for some individuals when verifying their identity - to improve accessibility, they are developing an alternative method which will enable users to verify their identity by logging into their bank account
• they have also worked with the Department for Work and Pensions (DWP) to generate additional KBV checks for people without a suitable credit history

A Post Office route is available in the UK as part of the One Login journey which supports users who wish to be guided/aided with verifying that their identity document is real and proves, to a level of confidence that they are who they claim to be. This route is however partly digital as the user is required to start and end the process online.

Evidence from customer contact with Companies House indicates that requiring all users to have photo ID may disproportionately impact older individuals and some people with disabilities. Complaints have highlighted that these groups are less likely to travel or drive and therefore may not hold commonly used forms of identification such as passports or driving licences. To address this, the Registrar’s may, in circumstances involving some element of a reasonable adjustment, allow individuals to verify using a variety of documentation aligned with the required standard of verification. Companies House consider the combination of age and affordability could also discriminate particularly against older and/or younger people for whom the cost of identity documentation may be prohibitive. To overcome this, the Registrar’s route allows individuals to attempt verification through a free knowledge-based route. Furthermore, documentation included within the verification standard is available at a range of price points, such as the Post Office PASS card which is approximately £15.

As mentioned in Part 1, Companies House has also implemented a dedicated team to support users who experience challenges verifying their identity using the One Login services due to one or more protected characteristics. This team can consider whether reasonable adjustments are necessary and whether individuals should be referred to an in-house team who are trained in scrutinising and processing identity documents. Referral will only be considered once users have been given detailed guidance and support to complete verification via the One Login journey.

For PSCs under 16 years, in some cases users will need the assistance from a parent or guardian. Some minors may face challenges with the verification checks due to looking different to their passport photo, or not having a mobile phone. We do not believe this is disproportionate to the policy objectives.

To mitigate impacts around race and nationality, the Registrar has supplemented the service with a procured software product which caters for countries currently excluded from the One Login service. This is supplemented with an in-house team to support users where additional checks are needed. This goes a long way to mitigating the issues related to race, however it is accepted that these users will experience a longer journey.

In relation to marriage and civil partnership, where the name on the register is different to the name on their identity documents we will ask why an individual is using a name other than the one used to verify. We do not require supporting documentation unless there is intelligence to indicate a potential risk. In those exceptional cases, obtaining a marriage certificate or proof of change of name is usually a common, accessible service.

To mitigate any impact related to gender reassignment, we will ask why (optional) an individual is using a name other than the one used to verify. However, it will not reference gender reassignment and we will not require supporting documentation unless there is intelligence to indicate a potential risk.

The accessibility of One Login and Companies House services and compliance with WCAG 2.2 level AA have been considered as part of meeting government accessibility requirements. One Login’s compliance is published at Accessibility statement for GOV.UK One Login - GOV.UK One Login. Companies House has published its accessibility statement for the remaining elements of the identity verification service.

Part 5 - Record your decision

As a result of your analysis, your findings will lead you to take one of the following courses of action

Proceed as planned with the policy or service	If you conclude that it should have no adverse or disproportionately negative impact on people who share a protected characteristic, and you are taking reasonable steps to advance equality of opportunity and foster good relations (which may mean taking no steps).	Yes
Adjust the policy or service	If you conclude it has a potentially adverse or disproportionately negative impact on people who share a relevant protected characteristic, or it does not take reasonable steps to advance equality of opportunity.	Not applicable
Proceed with your policy or service, despite potential negative impacts on equality and/or failure to advance equality if these can be justified	If the decision maker is clear precisely what the equality implications are in taking a decision, and they recognise the desirability of achieving the aims of equality duty, they can still choose to proceed without making any changes (short of anything that amounts to unlawful discrimination) if they consider that other factors justify it. It may be possible to introduce a mitigating action to address any issues identified.	Not applicable
Decide not to pursue the policy or service	If you find that a policy or service unlawfully discriminates or has an adverse impact that cannot be justified or mitigated, it might be necessary to rule it out.	Not applicable

Please outline why you have chosen this option

During the voluntary period and since the legal requirement for identity verification was commenced on 18 November 2025 the evidence shows that the Registrar’s verification routes are accessible for the vast majority of people. Of those that struggled, we believe there is effective support in place to aid compliance. The general principle is to provide support to allow people to have a reasonable opportunity to verify their identity via One Login or an ACSP. This does not mean they will be guaranteed to successfully verify their identity.

The pilot of the dedicated support team has shown that a number of users who were given additional guidance and support will successfully verify their identity through One Login, choose to access the service of an ACSP or resign as a director (due to reasons of capacity or personal choice).

Even with additional options for photo ID, support and guidance, we recognise that some people would not have a reasonable opportunity to verify their identity through One Login. In this case, the Registrar will provide a reasonable adjustment on a case-by-case basis to access the internal software package and/or in-house verification team. This will be vital in supporting customers and allowing Companies House to make reasonable adjustments as appropriate.

In conclusion, the identity verification service is sound and reasonable and proportionate steps have been taken to ensure the Registrar’s routes for identity verification are accessible and compliant with the Equality Act and public sector duty.

Part 6 - Monitor and review

Progress against actions will be monitored by the Equality, Diversity and Inclusion Steering Group on a regular basis.

Sign off by the decision maker

• Name: Sarah Whitehead
• Job title: Director of Strategy, Policy, Communications and Legal
• Date: 7 May 2026

This assessment will be reviewed monthly or as required by the identity verification project team.