On 17 September, three UK company directors became the first people ever convicted for breaching Companies House’s identity verification rules. Jill White and Marc Dillon, directors of a Reading property company, and Modinat Banjo, director of a London apparel business, were fined at City of London Magistrates’ Court after failing to verify their identities or file confirmation statements on time. The fines themselves were small, £80 to £307 plus costs, but the message is not: nine months after the identity verification deadline landed under the Economic Crime and Corporate Transparency Act 2023, the Insolvency Service has started prosecuting.
If you registered a company, or you’ve been a director for years and assumed nobody was really checking, this is the story that should get your attention. It’s the first real evidence that “verify your identity with Companies House” wasn’t a box-ticking exercise that quietly got forgotten. Enforcement has begun, and these three cases are very unlikely to be the last.
What actually happened
All new directors and people with significant control have had to verify their identity with Companies House, either directly or through an authorised agent, since the requirement came into force. Jill White carried on acting as a director, attending board meetings and signing off company accounts, despite never having verified her identity; she only completed the check in early September, right before her court date. Marc Dillon had verified himself but was still convicted, for knowingly letting White continue as an unverified director without taking reasonable steps to stop her. Modinat Banjo was convicted for a similar identity failure combined with a late confirmation statement.
The pattern worth noting: it isn’t just the unverified individual who’s exposed. Fellow directors who know about a colleague’s non-compliance and don’t act on it can be prosecuted too.
What to check in your business today
Don’t assume this is sorted just because your company was set up before the rules changed. Confirm three things this week:
- Every current director and every person with significant control has completed identity verification, either directly with Companies House or through a formal authorised corporate service provider.
- Your confirmation statement is up to date and was filed on time, since a late filing was part of two of these three convictions.
- If you know a co-director hasn’t verified their identity, you have a paper trail showing you raised it, rather than staying silent.
This is a five-minute check for most small businesses, but it’s exactly the kind of compliance task that quietly slips through the cracks when nobody owns it. It’s worth building into whatever governance routine your business already has, alongside things like reviewing your articles of association or shareholder agreements, rather than treating it as a one-off.
Get your paperwork in order properly
Cases like this are a useful nudge to look at your wider company documentation, not just the identity check itself. Board minutes, director service agreements, and shareholder resolutions all matter more once a regulator has shown it’s willing to prosecute over process failures, even ones this small. Smallprint’s legal document templates are built specifically for UK small businesses that need proper governance paperwork in place without paying solicitor rates for every routine document, which makes this exactly the kind of gap worth closing now rather than after an Insolvency Service letter arrives.
The takeaway
Three small fines have done more to prove Companies House means business than any government press release could. If you or a co-director haven’t verified your identity yet, do it this week rather than waiting for a reminder that might come with a summons attached.
