Three company directors have been fined in the first court cases brought over failures to comply with mandatory Companies House identity-verification requirements, moving the UK’s company-register reforms into an active enforcement phase.
The Insolvency Service secured convictions against Jill White and Marc Dillon, directors of White (Reading Properties) Limited, and Modinat Banjo, a director of J Isogony Apparel Limited, at City of London Magistrates’ Court on 16 September.
The prosecutions are the first brought by the Insolvency Service for offences connected specifically with the identity-verification regime introduced under the Economic Crime and Corporate Transparency Act 2023.
White continued acting as a director without verifying her identity, including participating in board-level decisions and signing company accounts. She completed the process in early September, around nine months after her deadline and shortly before the court hearing.
Dillon had completed his own identity verification but was prosecuted after failing to take reasonable steps to prevent White from continuing to act while she remained unverified. Both directors were also convicted after White (Reading Properties) Limited failed to file a confirmation statement on time.
White was fined £166, with £85 costs and a £66 victim surcharge. Dillon received a £307 fine, £85 costs, and a £123 surcharge.
Banjo also continued acting as a director before completing mandatory verification, including signing and delivering company accounts. She completed verification on or around 28 May 2026 and was also convicted in connection with a late confirmation statement. She was fined £80, ordered to pay £85 costs, and received a £32 victim surcharge.
Daniel Hart, senior criminal lawyer at the Insolvency Service, said: “There is no option to opt out.”
The cases establish an important practical boundary around the new regime. Directors are responsible for their own compliance, but the prosecution of Dillon shows that obligations can also arise where a verified director knowingly allows an unverified colleague to continue acting on behalf of a company.
Identity verification became a legal requirement for newly appointed directors from 18 November 2025. Existing directors are moving through a 12-month transition tied to their company’s confirmation-statement cycle.
Directors generally receive a personal code after successfully proving their identity, which must then be provided to Companies House as part of the relevant filing process. Failure to complete the required steps can prevent a company meeting associated statutory obligations.
The measures form part of a broader redesign of Companies House from a largely passive recipient of filings towards a register with stronger powers to verify, query, reject, and investigate information. The Economic Crime and Corporate Transparency Act was intended to make it harder to use UK corporate structures to conceal ownership, create false identities, or facilitate economic crime.
For legitimate companies, the immediate operational impact is more routine but still material. Boards, company secretaries, accountants, and corporate-service providers need to track verification status alongside existing filing deadlines rather than treating identity checks as a separate one-off administrative exercise.
The prosecutions also demonstrate that compliance cannot be delegated entirely to a finance function or external adviser. Directors retain statutory responsibilities even where filing activity is handled by someone else, while companies must ensure people exercising formal board roles are legally able to do so.
Verification can be completed free through the Companies House service or through an Authorised Corporate Service Provider. The system covers directors and people with significant control, while further elements of the wider company-register reform programme continue to be phased in.
The fines in the first three cases are relatively modest, but the enforcement step is more consequential than the monetary penalties alone. Companies House and the Insolvency Service had previously focused heavily on implementation, transition dates, and guidance. Court convictions now show that persistent non-compliance can lead to prosecution.
The next several months will bring a growing number of existing directors into their verification window as companies reach their confirmation-statement dates. Boards will need to know which directors and people with significant control have completed the process, whether their codes have been correctly linked to each relevant appointment, and whether unresolved issues could interrupt statutory filings.
The first convictions therefore turn identity verification from a future administrative consideration into an active governance requirement, with both individual directors and companies exposed where unverified people continue to exercise formal corporate responsibilities.
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