Only 9% of directors surveyed at multinational businesses with UK operations say their organisations have completed identity verification for all relevant directors and people with significant control, despite 84% reporting that they are prepared for the requirements.
The findings come from research published on 20 October 2026 by Vistra, which surveyed 300 directors at multinational organisations with a UK presence, including 50 respondents based in Britain.
The research identified a gap between respondents’ assessments of their organisations’ readiness and the practical work completed ahead of the end of the initial transition period introduced under the Economic Crime and Corporate Transparency Act 2023.
Respondents estimated that an average of 61% of the relevant directors and people with significant control (PSCs) in their organisations had completed identity verification. Only 9% reported that every relevant individual had completed the process.
Those figures are based on directors’ responses to Vistra’s survey rather than an independent examination of Companies House records. They do not establish that 91% of multinational businesses are in breach of the law.
Mandatory identity verification began on 18 November 2025, with a 12-month transition period for existing company directors and PSCs. The requirements are being introduced according to individual roles and applicable filing dates, rather than through a universal deadline requiring everyone to verify on 18 November 2026.
Under current Companies House guidance, existing directors must provide their personal code as part of their company’s next confirmation statement. A director holding appointments at several companies must provide the code separately for each relevant directorship, although the underlying identity verification normally needs to be completed only once.
People appointed as directors from 18 November 2025 must provide their personal code as part of their appointment or company incorporation filing.
PSCs have different arrangements. Each must provide a Companies House personal code within an individual 14-day period, with the dates determined by when the person became a PSC and whether they are also a director of the same company.
An existing PSC who is also a director must provide the code separately for both roles. The director requirement is fulfilled through the company’s confirmation statement, while the PSC requirement must be completed through the separate Companies House verification details service.
For someone who was already both a director and PSC when the requirements commenced, the PSC’s 14-day period starts on the day after the company’s confirmation statement date. Filing the statement early does not change that period.
An existing PSC who is not also a director of the same company must provide the code during the first 14 days of their birth month, as recorded by Companies House.
Someone becoming a PSC after 18 November 2025 can provide their code when first added to the register or within 14 days of being added.
These separate arrangements mean that a multinational business may need to coordinate several verification dates across its directors, PSCs and UK entities. Companies House makes the relevant dates available through its register.
Vistra’s survey suggests that some organisations have yet to establish complete internal records of the individuals covered. Only 20% of respondents said they had identified every director and PSC requiring verification.
A further 22% said they had obtained and recorded the necessary personal codes, while 26% reported checking that Companies House records for directors and PSCs were accurate.
Vistra also found inconsistencies in the underlying corporate information. Thirty per cent of respondents reported discrepancies between their internal records and information held by Companies House.
Missing supporting documentation, outdated director information and incorrect or incomplete PSC or ownership records were each identified by 29%. The categories may overlap and cannot be added together to calculate the proportion of organisations affected.
Cross-border management structures were another source of difficulty. Seventy-six per cent of respondents said verifying directors and PSCs based outside Britain had created additional compliance complexity.
Among those dealing with internationally based individuals, 27% cited coordination across jurisdictions and time zones as a barrier. Differences in identity documentation and concerns about data protection or information sharing were each reported by 24%.
Results varied geographically. US-based respondents reported the highest perceived preparedness, at 94%, but the lowest average completion level, at 55%.
EU respondents reported the highest average completion rate, at 73%, with 34% saying verification had been completed for all relevant directors and PSCs.
Among the 50 UK-based respondents, 86% considered their organisations prepared, but none reported full completion. Their estimated average completion level was 60%.
The survey also assessed the administrative work associated with wider corporate transparency and liability reforms. Two-thirds of respondents reported at least 10 additional working hours a month, with an average increase of 13.9 hours.
UK-based respondents reported an average increase of 17.3 hours a month. These figures concern the broader reform programme, not identity verification alone.
Meg Ogunsola, Vistra’s global head of entity management, said businesses needed accurate records of their corporate officers and controllers, clarity about who was responsible for completing verification and visibility of the individual deadlines applying to each person.
Identity verification can be completed directly through GOV.UK One Login or through an authorised corporate service provider. Once verified, an individual receives a personal code used to confirm their status for relevant company roles.
The legal requirements apply according to the person’s appointment and circumstances, irrespective of how prepared an organisation considers itself to be. Vistra’s research indicates that many surveyed businesses still have administrative and verification work outstanding as the transition progresses.
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