Companies House ID Verification: A Client Chaser Workflow for Accountants

Chase clients in three waves: an early notice that names each director and PSC, a reminder with the exact steps, and a phone call before the deadline. Track every person in a sheet with one status per row, and let AI draft the emails, never read the ID documents.

Timing changes the job. Verification became a legal requirement on 18 November 2025, which GOV.UK calls the start of a 12-month transition, not a deadline. GOV.UK publishes no single end date; Companies House's launch announcement expected everyone in scope to verify by mid-November 2026. Each person's due date sits inside that window, so by now the work is two lists: stragglers whose dates have passed or are days away, and new directors and PSCs who must verify as they are appointed. Both suit a tracker far better than a mass email.

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What GOV.UK says you are actually chasing

Before drafting anything, get the requirement right, because a chaser that gives wrong instructions creates more work than silence. These points come from the GOV.UK guidance pages as read in November 2026; check them again before you send, because Companies House has updated its guidance several times.

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• Existing directors (and equivalents, such as LLP members) must provide their Companies House personal code as part of the company's next confirmation statement. A director of three companies provides it for all three.
• People with significant control (PSCs) must verify and provide their personal code in a 14-day window. If the PSC is also a director, the window starts the day after the company's confirmation statement date. If the PSC is not a director, it is the first 14 days of their birth month. Someone who became a PSC after 18 November 2025 provides the code when first added to the register or within 14 days of being added. A PSC who cannot make it can request a 14-day extension through the GOV.UK service, but only before the deadline passes.
• A person who is both director and PSC of one company provides the code separately for each role.
• New directors provide the code in the appointment filing, and a new company needs a code for each director in the registration filing.
• A company cannot file its confirmation statement unless all its directors are verified, and GOV.UK warns that acting as a director after the deadline without verifying is an offence.
• A person can verify online with GOV.UK One Login if they hold an accepted photo ID such as a biometric passport, or ask a registered authorised agent (ACSP) to verify them.
• Verification for people who file at Companies House starts no earlier than November 2027, with at least six months' notice, according to Companies House's company-law changes site. Limited partnerships, corporate directors, corporate members of LLPs and officers of corporate PSCs follow "at a later date". Do not chase any of those yet.

Two consequences shape the workflow. First, your due dates come from the register and your confirmation statement calendar, not from a single date you pick. Second, the thing the client gives you is a code, not a document. That is the cleanest place to keep AI out of the sensitive part: the ID stays between the client, GOV.UK and (if you are registered) your verification system, and the code reaches you only through a secure channel when you file.

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Build the tracking sheet first

A spreadsheet is enough for most practices up to a few hundred companies. One row per person per company, because one director with four companies needs four rows with four different due dates. Here is the column set I would start with.

Use exactly five statuses so a filter gives a clean list: Not contacted, Notified, Code confirmed, Escalated and Filed. "Code confirmed" means the client told you they have verified and hold a code; it does not mean you saw the code. "Filed" means the confirmation statement or PSC step carrying the verification has gone through and you have checked the register.

The one rule for the notes column: no passport numbers, no driving licence details, no personal codes, no dates of birth beyond what the register already shows publicly. If a note would be harmful when forwarded to the wrong person, it does not belong there. That keeps the sheet safe to share with an AI assistant for drafting, which I come to below.

Working out each person's due date

This is the step most practices underestimate. Even this late in the transition, do it once, in bulk, before sending anything: it tells you who is overdue, who is due in the final weeks and who is already done. Export your client list with confirmation statement dates and each person's role and birth month, then add the due date by rule. You can also check the dates of a PSC's 14-day period on the Companies House register.

• Director: the next confirmation statement date for that company.
• Director and PSC of the same company: the director date for the director role, and the day after the confirmation statement date as the start of a 14-day window for the PSC role.
• PSC but not a director: the first day of their birth month, with the window running 14 days. GOV.UK gives the example that a 22 January birthday opens the window on 1 January.

A worked illustration, with made-up figures. Say a firm has 120 client companies. Listing every director and PSC role gives 190 rows but only 120 distinct people: 80 hold a single role, and 40 hold between two and five roles, 110 rows between them. The personal code belongs to the person, so each person verifies once, but the code still has to be provided for each company and each role. The firm is therefore chasing 120 people, not 190 rows. Sort the sheet by person first, so a director of four companies gets one email listing four due dates, not four emails.

Now split the 120 by status. In early November 2026 the sheet might show 104 people at "Code confirmed" or "Filed", 9 whose dates fall in the last weeks of the transition and 7 whose dates have already passed (104 + 9 + 7 = 120). That split, not the total, decides the week's work: the 9 get the compressed chase below, and the 7 go straight to "Escalated" with a phone call today.

The sort matters more than it sounds. A client who receives four separate emails in a week from the same firm stops reading them by the third. One email with a small table of dates gets answered. You will see this in the sheet: if the "Notified" count rises but "Code confirmed" stays flat, the emails are too numerous, too vague, or both.

Three chase waves on two different clocks

Space the chasers around each person's due date, not around a calendar week. The waves stay the same; the spacing depends on whether you are clearing the end of the transition or handling a new appointment.

1. Wave one: the notice. Name each role, give the steps, ask for a one-line reply when done.
2. Wave two: the reminder. Short, restates the steps, offers help. Send only to people still at "Notified".
3. Wave three: a phone call, then a two-line email. Anyone still not confirmed moves to "Escalated" and the partner is told.

Clearing the transition (November 2026). For people whose dates fall in the final weeks, send wave one today, phone within three working days and send the wave-three email the same afternoon. Skip the middle step; there is no time for it, and pretending otherwise only delays the call. For people whose date has already passed, start at wave three. Their company cannot file its confirmation statement until every director is verified, and a PSC's extension can only be requested before the deadline, so a missed PSC window cannot be rescued that way.

Business as usual (from now on). Most new chasing will come from appointments. A new director's code goes into the appointment filing, so make verification part of the appointment request: wave one the day the client tells you about the new director, wave two after five working days, a call after ten, and no appointment filing until the client confirms the code. A new PSC has 14 days from being added, so compress to day one, day five and day ten. For an incorporation, ask for every director's code before you prepare the registration filing.

Those day counts are starting numbers, not rules. A practice with mostly sole-director clients who answer email within a day can shorten them. A practice with clients abroad or older clients who prefer paper should start earlier, because some people need time to find a suitable photo ID or book an appointment with an authorised agent.

Email templates, filled in

These are illustrative and written for a practice that is not verifying clients itself, so the client verifies online. Swap the route paragraph if you are a registered agent. Keep the language plain: your clients are running electrical, plumbing or roofing businesses, not reading statute.

Wave one

Subject: Action needed: verify your identity with Companies House by [date]

Hi [first name],

Companies House now requires every director and person with significant
control to verify their identity. For [Company name] we need this done by
[due date] because it ties to your confirmation statement.

What to do (a few minutes online for most people):
1. Go to GOV.UK and search "verify your identity for Companies House".
2. Sign in to or create a GOV.UK One Login and follow the steps. You will
   need a biometric passport or another accepted photo ID.
3. At the end you will be given a Companies House personal code.
4. Reply to this email with just "Done" so we can tick you off. Please do
   not email us the code, your passport or any ID: we will ask for the
   code through [secure portal] when we prepare the filing.

If you do not have a suitable photo ID, tell us and we will explain the
other routes.

Thanks,
[your name]

Notice the instruction about how the code reaches you. GOV.UK tells people to share their personal code only with those they trust to file for them and to keep it secure, so it belongs in your secure portal, not an inbox. It is there for the client's protection and for yours: an inbox full of passport scans and codes is a liability. If you do not have a portal, ask the director to enter the code into the filing themselves on a short call.

Wave two

Subject: Reminder: Companies House verification for [Company name]

Hi [first name],

A quick reminder: we have not yet heard that you have verified your
identity. The deadline for [Company name] is [due date], [N] days away.

It takes a few minutes online, as in my last email. If it helps, we can
book a call and talk you through it.

Reply "Done" once finished.

[your name]

Wave three, after the phone call

Subject: Following our call: verification for [Company name]

Hi [first name],

Thanks for talking this through today. As agreed, you will complete the
verification by [date] and reply "Done". Without a personal code we
cannot file the confirmation statement for [Company name], so [date]
is the last day we can leave it.

[your name]

The third template states the consequence once, calmly, in writing. A short written record after a call is what you want on file if a late filing becomes a discussion later.

Using AI for the wording, and what it never sees

AI helps with three jobs here: personalising the templates for different client types, writing a firmer version for the people who have ignored two emails, and summarising the sheet into a Monday list for the partner. It should never see ID documents, personal codes or screenshots of a verification screen. The rule is simple: give it the sheet columns, not the evidence.

A prompt that works on the redacted tracker (first names only, no notes column):

I run an accountancy practice. Below are rows from our verification
tracker: first name, role, due date, status, days since last contact.

Rows:
[paste 8 rows]

For each row with status "Notified" and more than 20 days since last
contact, write a two-sentence reminder in plain English. Do not threaten.
Do not mention fines. Keep each under 50 words. Output as a table with
columns: first name, subject line, body.

Here is the kind of output you might get, labelled illustrative, and what to fix in it. For a director whose due date is nine days away, the draft might say: "Hi [first name], just checking in. Your verification for [Company name] is due in 9 days and we have not seen you confirm yet. Reply Done once you have finished, or call us if you are stuck." Good. A second draft for another person might say "failure to verify may result in penalties". That breaches the no-threat instruction and, more importantly, states a legal consequence you have not verified for that client's situation. Delete it. You are not the regulator and the email is not the place to quote one.

Check every draft for three things before it goes: the due date matches the sheet (AI will occasionally swap two rows), the role is right (a PSC who is not a director has a different window), and there is no invented step. A common slip is the model adding "upload a photo of your passport to our portal". If that is not what you ask clients to do, take it out.

If you want a broader look at what prompts help across a practice, the accountants' prompt pack has ten, and the readiness checklist for professional firms covers the data rules you should set before any client name reaches an AI tool.

Keeping ID documents out of chatbots

This needs its own section because it is where a well-meant shortcut goes wrong. A staff member with a photo of a passport and an AI app on their phone can ask "is this valid?" in one tap. Do not allow it. A consumer chatbot is not your anti-money-laundering system. Even where a business plan does not train on your content by default, you have still moved a client's identity document to a third party without a reason your engagement letter or privacy notice covers.

Put three lines in your firm's AI rules:

• No images or scans of identity documents in any AI tool, ever.
• No personal codes in any AI tool, the tracker, or email.
• AI is fed only the redacted tracker columns: first name, role, due date, status.

If you are registered as an authorised agent and verify clients yourself, document checks happen inside whatever verification route you use, under your existing anti-money-laundering procedures, and none of that goes near a chatbot. If you are not registered, you never touch the document at all, which is the safest position and a good argument for the self-service route in the email above. The tutorial on which AML client checks an accountant can automate draws the same line across the rest of your client due diligence.

Five client types and what to change for each

The sole director who answers in minutes. One email, the steps, a reply of "Done". Do not send three waves; one reminder is plenty.

The director with four companies. One email with a four-row table: company, due date. Tell them the code is one per person, so they verify once. That removes the most common confusion, which is believing each company needs a separate verification.

The silent PSC who is not a director. Their window is tied to their birth month, and they are not on your confirmation statement workflow, so nothing prompts them. On GOV.UK's birth-month rule, a November birthday means a window of 1 to 14 November 2026, open now; for any other birth month the window has already passed during the transition. Check the register for their dates and chase them directly, or through the director if you have no contact. If they are still inside the window and cannot finish, the extension request is the first thing to mention.

The client with no suitable photo ID. GOV.UK lists other One Login routes for some people, such as bank or building society details with security questions, or an in-person check at a Post Office, plus verification through an authorised agent, who will ask for documents from an approved list. Change the email: skip the self-service steps and offer a call. Set status to "Escalated" early, because arranging an alternative takes longer than a few minutes.

The client who verified already. Some will have done it before you wrote. Ask them to reply with the date, and mark them "Code confirmed". Do not ask them to verify again. If they have lost the code, GOV.UK says it is shown under "Manage account" when they sign in to Companies House, and anyone who verified with One Login after 8 July 2026 was also sent it by email.

A weekly Monday routine that takes twenty minutes

1. Filter the sheet to "Next action date" on or before today. That is your work list.
2. Sort by role and due date so the closest deadlines come first.
3. Send the wave that matches each person's status, using the templates.
4. Update "Last contact" and set a new "Next action date" in the same sitting.
5. Count the rows by status and paste the five numbers into a short note for the partner.
6. Pull any row within 14 days of its due date that is not "Code confirmed" into a phone list.

For the partner note, an AI summary is useful, as long as the input is the counts and the first names of the Escalated rows. Ask for a five-line summary and a list of the three people most at risk. You get a readable briefing in a minute, and the sensitive material never leaves your own systems.

How to tell the workflow is working

Four numbers tell you, and you can read them off the sheet in a minute. The first is the number of people whose date has passed and who are not yet at "Code confirmed" or "Filed". After mid-November 2026 that should be a short list of names, each with a call booked, not a percentage. The second is the average number of waves needed per person; if it creeps above two, your first email is unclear. The third is the count of Escalated rows, which should shrink every week. The fourth is the number of rows with an empty next action date, which should always be zero.

One realistic mistake and how it showed up: a practice sorted its sheet by company, not by person, and a director of five companies received five emails over four days. Two replied "Done" in separate messages, and one of the five rows was marked Filed by mistake because the reply was attached to the wrong company. The fix was to add a person key, send one email per person, and mark "Filed" only after checking the register for that company.

The same status ladder works for other deadline chasing in a practice: the tutorial on chasing missing client records before deadlines applies it to year-end paperwork. And if the next job in your practice is sending clients a structured document request, the client tax organiser tutorial pairs well with this one.

What to say when the answer is "I'll do it later"

Most chasing is not about an angry client. It is about a client who will do it later. Give them something finite and a date. "Can you do it before Friday and reply Done?" gets a better result than "please verify as soon as possible". Add one line about the effect on them: the code is needed to complete their company's confirmation statement, and without it the firm cannot file for them. That is accurate according to the guidance, and it is about their company, not about your convenience.

For the stubborn ones, make the phone call the main tool, and write the follow-up email within the hour. Record the call in the notes column as "called, agreed [date]". If the date passes, the row moves to Escalated and the partner decides whether to write a formal letter, which is a judgement for the partner and, where there is doubt, a solicitor.

One last check before you send anything: open the GOV.UK pages named in the sources line and compare each date, step and route in your templates with what they say that day. The guidance has been revised more than once, and a template written in October can be out of date by December. Put a review date in the tracker's first row and treat it like any other due date.

Questions accountants ask while chasing ID verification

Can I paste a client's passport into a chatbot to check it?

No. Identity documents should stay in the systems your firm already uses for anti-money-laundering checks. Use AI only for wording and for the tracking sheet, which holds names, statuses and dates but never document images, numbers or personal codes.

What if a client keeps ignoring the chasers?

Move them to the escalation status, phone them, and tell the partner. Record each attempt with a date. If a director cannot file a confirmation statement without a personal code, say so plainly in writing and keep a copy on file.

Should the tracker store personal codes?

No. GOV.UK says to share the personal code only with people you trust to file for you, and to keep it secure. Record only that the client confirmed they have one, plus the date, and collect the code itself through your secure portal when you prepare the filing.

Do I need to be registered as an agent to chase clients?

No. Chasing is ordinary client communication. Registration as an authorised agent (ACSP) matters if you verify clients' identities yourself, and Companies House says firms will need it to file for clients from no earlier than November 2027, with at least six months' notice. Check GOV.UK before promising either service.

Can a PSC get more time to verify?

Yes. The GOV.UK service for providing PSC verification details lets a PSC request a 14-day extension, but only before their deadline passes. Record the request date and the new deadline in the tracker, and run the chase from the new date rather than the old one.

Further reads

• AI for Chartered Accountants: What to Tell Clients About Your AI Use — What to tell clients about your firm's AI use.
• AI Engagement Letters for Accountants: Faster Drafts, Clear Scope — Put chasing duties and scope into the engagement letter.
• ChatGPT Prompts for Bookkeepers: Client Queries, Chasers, Notes — Prompts for client queries and chasers in a bookkeeping practice.
• 7 AI Mistakes That Put an Accounting Firm's Client Trust at Risk — AI slips that cost an accounting firm its clients' trust.
• AI in KYC for a Small Wealth or Advice Firm: Checks That Stay Human — Which identity checks should stay with a person.
• AI Tools and AI Development: The Complete 2026 Guide — the AI hub, including every tutorial in the AI-for-business series.

Sources: GOV.UK guidance 'Verify your identity for Companies House', 'When you need to verify your identity for Companies House', 'Verifying your identity for Companies House', 'Companies House personal codes for identity verification' and the PSC verification service page; Companies House's August 2025 rollout announcement and its company-law changes campaign site (all read 4 November 2026).