Before the Instruction Lands: A 2026 Identity Verification Routine for UK Advisory Firms
Photo: Metro Centric, CC BY 2.0, via Wikimedia Commons
Companies House identity verification is now a settled part of UK company administration. Following the phased rollout under the Economic Crime and Corporate Transparency Act 2023, the question for advisory firms in 2026 is no longer whether verification applies, but whether onboarding can absorb it without derailing a client’s timetable. Too often verification sits at the end of the intake pack: the instruction is accepted, the matter is opened, and only then does someone discover that a director has not completed the necessary check. The result is an awkward pause, a compressed deadline, and a client who associates the firm with delay rather than diligence.
The checklist below is for UK advisory firms — legal, accountancy and consultancy — that accept instructions from companies, LLPs and their controllers. It treats identity verification as a condition of engagement, not a clerical afterthought.
1. Settle the scope rule before the first meeting
The firm should decide, in advance, which individuals it will verify for each client type. At a minimum, the rule should cover directors, people with significant control and LLP members. Where an entity is the client, the firm should also identify the beneficial owners and any individual who will authenticate filings or give instructions under the firm’s authority.
Two practical points are easily missed. First, Companies House verification and anti-money laundering due diligence are related but not identical. One confirms identity for the register; the other supports the firm’s risk assessment. The file should show both, without pretending one replaces the other. Second, if the firm uses an authorised corporate service provider, the onboarding note should say who verified what. A reference to “verified via ACSP” is not enough if no one can explain which individuals were covered.
2. Build a single evidence file
For each individual, record the verification route, the date, the outcome and any unique reference available. Add the name of the person who reviewed the result and a short note of any discrepancy. If the client has already verified through Companies House, capture the confirmation rather than asking for the same information twice.
Retention should follow the firm’s AML and data protection policies. Keep what is necessary, for as long as necessary, and no longer. A common weakness is a folder of passport scans with no index: plenty of data, little evidence. A short, indexed record is more useful than a large, undocumented archive.
3. Put the condition in the engagement letter
The engagement letter should make verification a condition of the instruction, not a favour requested after work begins. Clear wording helps both sides. It might say that the client will ensure every individual requiring verification completes it promptly and provides accurate information; that the firm may suspend work or decline to file until verification is recorded; and that the firm is not responsible for delays caused by the client or by Companies House.
The clause should also deal with third parties. If an accountant, lawyer or company formation agent is acting, the client should authorise the firm to share the information needed to complete verification. Without that permission, the firm can find itself holding an incomplete file while the clock runs.
4. Triage time-sensitive instructions
Not every instruction can wait for a full onboarding cycle. The firm needs a documented route for urgent matters, not an informal habit of starting first and verifying later. A workable approach is to separate the instruction into two decisions: whether the firm is willing to act, and whether it is willing to start before verification is complete.
The first decision belongs to the engagement partner. The second should require a written note: what is missing, why the delay matters, what work is being authorised, and who accepts the risk. That note is not bureaucracy for its own sake. It gives the firm a defensible record if the client later complains about delay or if a file is reviewed.
5. Give onboarding a clock and an owner
Verification stalls when nobody owns it. Name one person in the firm who is responsible for the onboarding file, even if others collect the evidence. Set internal points for follow-up: a reminder on day two, an escalation on day five, and a partner decision on day seven. The exact numbers matter less than the discipline of having them.
The client should see the same clock. A short onboarding note can explain what is needed, who must provide it and what happens next. That is more effective than a series of apologetic emails asking for one more document.
6. Review the routine every quarter
A checklist is only useful if it changes. Each quarter, take a small sample of completed onboarding files and ask four questions. Was the scope rule applied correctly? Was the evidence easy to find? Did any instruction start before verification was complete, and was that recorded? How long did verification take from first request to recorded outcome?
The answers will usually point to one or two fixes: a clearer engagement letter, a better index, or an earlier conversation with the client. Those small changes protect the firm’s timetable and its professional standing.
Identity verification will not win new business on its own. But a firm that handles it calmly, consistently and early avoids the bottleneck that turns a straightforward instruction into a strained relationship. In 2026, that is a modest advantage worth having.
