Director Identity Verification: Final Explainer

Mapping the ACSP, One Login, and Post Office routes The risks of centralised records and function creep into a mandatory national digital ID system

Centralisation today, mandatory ID tomorrow?

Introduction

I have written this article to map out the director identity verification process as clearly as possible, to make life easier for everyone trying to understand it. The issue is complex, so the article is long — you may want to print it off and read it at your leisure.

What follows is based on current law, policy and guidance and my interpretation of it. While I may not have captured every nuance correctly, I have tried to explain in plain English how I believe the process works, and what systems are involved.

It was important for me to write this article because all directors should be aware that every verification route offered to them currently carries inherent issues: data handling risks, centralisation of records, and the potential for function creep. The ACSP route does not currently involve biometric processing, but this does not make it a “better” option — and why that is the case is explained below.

Here is how this article is structured:

• Part 1 sets out how ACSP route for director verification works, explaining the role of authorised agents, how they use One Login, and that the data they submit on behalf of directors results in centralised records.

• Part 2 explains personal One Login accounts and the Post Office partner route for director verification, including how biometric checks are performed and why these routes also result in centralised records, but with an added biometric layer.

• Part 3 provides a comparison table of director verification routes, so readers can see the differences side by side.

• Part 4 explores other risk areas connected to the issue, such as data retention, accountability gaps, and technical vulnerabilities.

• Part 5 considers the potential for function creep across several domains, showing how company director data held centrally as a result of this verification system, could expand into broader data‑sharing regimes or mandatory digital ID systems, without needing further consent from the data subject.

• Part 6 wraps everything up with a cheat sheet of the major flaws and issues with the director verification process, which you can use as talking points.

• Finally, the Appendix defines how function creep could change the way directors’ data is used, and explains how this could happen through policy or framework updates rather than new legislation — something you may also want to keep handy.

This is the last article I am going to write on the company directors’ verification issue, because after this I think I will have said all I can say about it. Anyone who has watched my interviews or read my previous work knows how strongly I feel: I dissolved my own company some time ago partly, (not fully as there were other reasons), in protest against the director verification requirements. In my view, these requirements are all leading to data grabbing and the installation of a wider architecture of control through mandatory digital ID.

Looking ahead, I intend to focus more deeply on One Login and Gov Wallet. Factually, One Login is the UK’s centralised digital ID platform, designed to enable federated data identity verification sharing across government departments. Gov Wallet sits within One Login and is the permissions based aspect of the system. My concern is that One Login and Gov Wallet matters not just for directors, but for ANYONE using government services, and I really think that people need to know the dangers of this system, and why those dangers matter to people’s freedom. In my opinion, the government is intent on getting everyone onto One Login, and I believe that the reason for this is function creep and further data usage of the kind I discuss below. However, it is important to note here that I believe that the ACSP route for directors also carries the same function creep and data usage risks as One Login.

If you are asking yourself why this mass data grabbing exercise is unfolding everywhere, it is happening because digital ID is needed for the digital currency agenda. Digital currency is needed because the current fiat debt based system is collapsing under its own weight. Due to the interest due on all debt constantly created, it has become, effectively, unservicable. A switch to a digital model, still based on debt of course, but collateralising physical and non physical assets as tokens on which debt can issued, (and therefore new digital currency created), is what is desired by the international criminal cartel of bankers, governments and those above them.

Digital currency cannot operate at scale without digital ID. This is why it is so important to refuse participation in the UK’s One Login and Gov Wallet systems. At the same time, we must recognise that information collected by other means, and held in centralised government databases—such as via the ACSP route for company directors—is just as problematic as One Login. In fact, any attempt by government to collect sensitive, identifiable data now, should be seen as a stealth method of gathering the information needed to advance a mandatory digital ID rollout, and this is particularly relevant to those unwilling or unable to join One Login. Data harvested through such stealth exercises will be used interoperably, just as much as data in One Login will. So, put simply, mass government data collection by means other than One Login must now be viewed as part of the same digital ID agenda merely being pursued through different channels.

The bottom line to all of this is that people either want to stop digital ID, or they don’t. If you do, then now is the time to recognise that sacrifices may be required. Refusing to comply with ongoing data capture could mean loss of company status, earnings, or assets if you reject director verification requirements; loss of benefits if you refuse to apply through One Login when no alternative route exists; or loss of access to other government services and rights if you will not hand over your data for collation and interoperability. This is the reality.

My fear, therefore, is that not enough people will make a stand against “laws” coercing them to relinquish data, or “rules” requiring them to apply for benefits and services in ways that enable data harvesting for digital ID purposes. That being the case, we will not win this battle—and that will mean saying goodbye to ever being able to refuse future rollouts of anything imposed by those who claim to be “in power”.

If you are on the fence about resisting this issue—perhaps a company director who knows it’s dangerous to give over data but fear losing your business, or someone who feels forced to use One Login but feel you must to claim benefits or pension etc—consider this: we are at a moment where people MUST either take a stand now, accepting the risk of losing certain things in order to resist this dystopian nightmare becoming a reality, or acquiesce and lose everything by signing up to it and making the dystopian reality happen through choice. The worst part of acquiescence is that those going along with it all will be locking their children, grandchildren, and everyone else’s into the nightmare that will inevitably unfold if mandatory interoperable digital ID makes it over the finish line.

The question then becomes: how brave are people willing to be on this issue?” I guess we are going to find out pretty soon….

With all the above said, let’s now dive into the real purpose of this article.

Part 1 –Authorised Corporate Service Provider (ACSP) Verification Route

ACSPs—also referred to as Companies House authorised agents—submit director identity verifications using their own authorised agent accounts. These agent accounts are through One Login, the government’s central authentication and verification service. This means that whilst directors choosing this route can avoid creating or using a personal One Login for verification purposes, (because the ACSP handles the process), the director’s identity details are still submitted into Companies House systems, creating a centralised government database of verification records. The details are not stored in the One Login system itself, but One Login is the mandatory gateway through which ACSPs access Companies House services for the purposes of director verification.

How ACSPs get Agent Accounts

• ACSPs must register with Companies House to obtain a dedicated authorised agent account. This account is used to manage identity verifications and, in future, it will manage all filings on behalf of clients.

• Eligible entities (e.g., accountants, solicitors, or company formation agents supervised by a UK anti‑money laundering (AML) body) apply via the official service at find-and-update.company-information.service.gov.uk/register-as-companies-house-authorised-agent. Upon approval, Companies House creates the agent account.

• The account allows ACSPs to add and manage users with roles such as administrator or standard user. ACSPs must retain identity verification records for seven years, in line with Companies House guidance.

• ACSPs use their agent account to notify Companies House that they have completed identity checks on a director’s behalf. The ACSP registration service launched in March 2025, and voluntary identity verification began in April 2025.

• In future, as reforms under the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023) are phased in through spring 2026, ACSP registration will also be required for ALL DOCUMENT filing on behalf of clients under the “File as an authorised agent” option.

Are These Agent Accounts Linked to GOV.UK One Login?

• Yes because access to the ACSP agent account requires signing in to Companies House services, which now integrates with GOV.UK One Login as the primary authentication method.

• Users sign in here where GOV.UK One Login is explicitly required (or can be created during the process). This provides centralised access across government services, including Companies House agent functionalities.

• When the ACSP performs the director identity verification checks, they submit the results through their agent account. This acts as an alternative pathway, enabling directors to avoid setting up a personal One Login account. However, it does not bypass One Login entirely, because the ACSP themselves must use One Login to access Companies House.

What happens when an ACSP verifies a director

• ACSPs rely on One Login to access Companies House services. Directors verified via ACSPs do not need their own personal One Login account, but their identity details are submitted into Companies House systems by the ACSP. These details form part of Companies House’s internal centralised record and database of director verification outcomes, linked to a permanent personal code.

• When ACSPs verify directors, they enter details from identity documents (passport or driving licence) into their One Login‑linked agent account. These details include the person’s name, date of birth, home address, email, document type, reference number, expiry date, and country of issue. Companies House then issues an 11‑character personal code to the individual and record the verification outcome. The outcome — (but not the underlying document details) — is visible on the public register, while ACSPs must retain copies of the documents privately for seven years.

• Although UK passports and driving licences are biometric documents, current Companies House guidance (see below for the problem with this), states that biometric data is not shared in the ACSP route. ACSPs submit only textual metadata (document numbers, expiry dates, country of issue) and attest that checks meet the Companies House standard. No chip‑reading, facial matching, or biometric extraction is required or transmitted to Companies House through the ACSP route. However, even though the ACSP route avoids biometric transmission it still results in centralised records within Companies House. In my view, it is the centralisation that carries the risk of function creep into wider mandatory digital ID systems - discussed below.

Key context

• Centralised government database: Using the ACSP route still means that Companies House receives company director data which is centrally stores along with the verification outcome. This creates a centralised government repository of director identity verification data, even though the verification is the only public outcome shown.

• Upcoming changes: From spring 2026, businesses filing any documents on behalf of clients – e.g. company accounts- will need to register as ACSPs, expanding the requirement for more accountants and other agents to have to use the One Login system.

Part 2 – Personal One Login and Post Office Partner Verification Routes

Directors who choose not to verify their identity through an ACSP must instead use a personal One Login account, either completing the process themselves end to end or starting it via the Post Office partner route. One Login is the mandatory gateway for both, ensuring that all verification outcomes from these two routes flow into Companies House regardless of the route chosen. Both pathways involve biometric processing.

In the full One Login route, directors create their own account and complete verification by submitting passport or driving licence details alongside a selfie, which is matched against the biometric chip data in the passport or against DVLA records for driving licences by “trusted” providers such as Yoti. In the Post Office route, the director begins on One Login by entering certain details, then visits a branch where staff check the passport or driving licence and capture a live facial image to verify it against the document presented in person.

Hence both routes differ in how the biometric check is performed, but both share the same biometric result. They also share the same outcome as ACSP verification: the verification result is submitted into Companies House systems and linked to the director’s permanent personal code.

Please note that it is only the verification status that is publicly visible on the register whatever verification route is chosen; the biometric and other data itself is not published, but crucially this underlying biometric and other data is what creates the centralised government repository of verification records, just as with the ACSP route.

How Personal One Login Verification Works

• Direct account creation: Directors or PSCs choosing this route must create a personal GOV.UK One Login account.

• Biometric processing: Verification involves uploading a passport or driving licence and completing a biometric check. This typically means a selfie or live facial image matched against the biometric chip data in the passport or licence. “Trusted” providers such as Yoti handle this process under contract.

• Reusable identity profile: Once verified, the individual’s One Login account becomes a reusable identity profile across government services. This means the verification is not a one‑off event but a persistent credential.

• Submission to Companies House: The verification outcome (linked to the individual’s permanent Companies House personal code) is stored in Companies House systems, creating the same centralised record as with ACSP verification.

How the Post Office Partner Route Works

• Start on One Login: The director creates or signs in to a personal One Login account and begins the verification journey online to generate the necessary reference for an in‑branch Post Office check.

• In‑person verification: The director then visits a designated Post Office branch with their passport or driving licence to complete verification.

• Biometric capture: Post Office staff capture a live facial image and verify it against the presented document as part of the biometric check.

• Submission to Companies House: The verification outcome is transmitted via One Login infrastructure and stored by Companies House, linked to the director’s permanent personal code.

• Centralisation persists: As with all routes, the verification outcome becomes part of the centralised Companies House record.

Key Context

• Biometric distinction: Unlike the ACSP route, both the personal One Login and Post Office route involve biometric processing (selfie or live facial matching).

• Centralisation persists: Regardless of route, Companies House retains the verification outcome and identifiers in its systems. This creates the same centralised government database of director identity records.

• Function creep risk: Because the centralised record exists in all routes, the potential for function creep remains across all routes. The personal and Post Office routes also add biometric processing risks, while the ACSP route adds long‑term retention risks. None can be considered “better” — they simply expose directors to both similar, but also different, vulnerabilities.

Summary of Parts 1 and 2

Personal One Login verification involves biometric processing (selfie matched against the biometric chip in passports or DVLA records for driving licences) via providers such as Yoti. The Post Office partner route also requires biometrics, with staff capturing a live facial image against the passport or licence presented in branch. These biometric elements are often seen as the key distinctions that make the ACSP route “better,” since ACSPs do not transmit biometrics. However, the ACSP route is not inherently better or safer. Whilst it avoids biometric transmission, the verification outcome and identifiers are still centralised within Companies House and linked to a permanent personal code. This means the potential for function creep exists across all routes. In addition, ACSPs must retain copies of identity documents for seven years, creating dual exposure and fragmented accountability. In practice, the ACSP route simply trades biometric risk for long‑term retention risk.

In addition, One Login is designed as a federated authentication service across government departments. Current guidance states that all director verification submissions, including those obtained by ACSPs, are siloed into Companies House systems and used only for verification. However, this is not a permanent guarantee. Directors therefore face the same risks of centralisation regardless of verification route, with the long‑term trajectory of their submitted data shaped by evolving frameworks and shifting policy rather than parliamentary legislation. Such changes may be rapid, opaque, and beyond direct oversight — this is the essence of function creep, where data collected for one purpose can be cross‑shared without explicit authority into broader regimes or repurposed into a wider mandatory digital ID system, such as a future Britcard.

Key points to take away:

• All routes — ACSP, personal One Login, and Post Office partner — result in the same Companies House personal code and centralised record.

• The only difference lies in data handling: ACSPs submit document metadata and retain copies for seven years, while One Login routes involve biometric checks.

• Current limits on biometric sharing and federated data sharing are policy choices, not permanent guarantees.

• All directors face risks of centralisation and function creep, meaning their data could ultimately be repurposed into a mandatory digital ID system (e.g. a Britcard), whichever route they choose.

Part 3 - Comparison of Verification Routes for Directors

Below I have prepared a table to help people visualise how the different director verification routes discussed above in Part 1 and Part 2, operate, as some people prefer to see a side by side comparison.

Part 4 – Other risk areas

Hopefully by now you can see that all three routes for director verification centralise sensitive identifiers within Companies House and link them to a permanent personal code. And whilst the ACSP route avoids biometric transmission and a personal One Login profile creation, it still requires directors to trade privacy for utility and risks future function creep into data federation and/or a reusable digital ID system.

The personal One Login route (which includes the Post office partner route) adds biometric checks and reusable profiles that do not currently exist within the ACSP route, but these routes still carry the same risk of future function creep into further data federation and/or a reusable digital ID system.

Hence, the overriding concern here is the centralisation aspect: once identifiers are tied to Companies House records, the system creates a durable identity spine. From that point, function creep becomes a real risk — systems built for one purpose can broaden into wider data‑sharing regimes which then become mandatory. And worse, such changes are often introduced through quiet policy updates or inter‑departmental agreements, NOT fresh legislation debated and passed by Parliament. This is discussed in Part 5. In advance, below, I have summarised in a table other potential risks associated with the directors’ verification issue, for people to consider.

Part 5 - Potential Outcomes of Function Creep

In this article I have established that director verification centralises sensitive identifiers within Companies House and links them to a permanent personal code. I also established that whilst current guidance limits the use of this data, the existence of a durable identity spine creates the conditions for function creep — where systems built for one purpose gradually broaden into wider data‑sharing regimes, often through policy changes or inter‑departmental agreements rather than fresh legislation debated in Parliament.

Below I have listed possible outcomes that could arise if function creep occurs. These are extrapolations based on existing systems, consultations, and precedents, so they are not confirmed plans. However, because such changes could be introduced quietly through policy rather than legislation, it is unlikely that any official guidance about this area publicly exists, let alone sets out possible changes clearly.

Part 6 –Wrapping It All Up – A cheat sheet of major flaws which you can use as talking points

• Directors are the first large civilian population systematically enrolled into a centralised verification regime, making them a test case for wider mandatory digital identity frameworks. This early targeting matters: by experimenting on directors first, the government establishes the infrastructure and normalises the practice of linking strong identity tokens (passport or driving licence numbers) to economic activity. Once proven on directors, the same model can be rapidly extended to the wider population, paving the way for a mandatory national digital ID such as a Britcard.

• The system of company director verification dramatically accelerates function creep, particularly as One Login is central to the process. Function creep poses the risk that sensitive data submitted during this process (and indeed any other process in the future) will be shared and used in other ways as desired at some future point, without further consent.

• Company director verification is effectively mandatory digital ID for directors, as it is the first time the UK government has systematically collected and indefinitely stored passport or driving‑licence numbers for millions of people outside the context of applying for a passport, licence, or benefit.

• The legal basis for company director verification and holding the data submitted is “public task” under the Companies Act — a broad justification that can easily be expanded to cover new uses, including a future national digital ID or Britcard.

• By verifying through any route — ACSP, personal One Login, or Post Office partner (which also begins on One Login) — directors create a permanent, re‑identifiable government‑held linkage between one of the strongest identity tokens in the UK (passport/DL number) and their economic activity. Once this link exists, further uses may require no new consent — only a policy decision or data‑sharing gateway.

• There is no genuine non‑digital route for directors to verify their identity, creating risks from a data security perspective by forcing reliance on digital systems alone. In addition, the Post Office and ACSP routes incur costs and are marketed as ‘digital alternatives’ — when in fact they are not — and which may engage Public Sector Equality Duty obligations by disproportionately affecting certain groups.

• One Login has no valid safety certification and any director using this route should be told this. In May 2025, One Login lost its accreditation under the UK’s Digital Identity and Attributes Trust Framework (DIATF). It currently meets only 21 of 39 outcomes in the National Cyber Security Centre’s Cyber Assessment Framework, meaning it falls short of full compliance (Bramble Hub, Mobile ID World). Red‑team security tests have also exposed vulnerabilities. Independent penetration testing in March 2025 found that privileged access could be compromised without detection. In May 2025, The Telegraph reported that One Login outright failed a red‑team test, raising concerns about national‑level risks if the platform is expanded (Telegraph). Whistleblower accounts also allege systemic flaws. Multiple insiders have claimed that One Login suffers from “massive security failures,” including insecure privileged access, offshore development outside the UK, and over 500,000 unresolved critical or high risks. Reports suggest warnings from the Cabinet Office and NCSC about serious data protection failings were ignored (Reclaim The Net, UK Reloaded, Cybersecurity Now, NewsTarget).

Appendix

How changes to the use of directors data held in the Companies House identity verification system could happen through policy or framework updates rather than new legislation.

1. Legal foundation (ECCTA 2023)

• The Economic Crime and Corporate Transparency Act 2023 (ECCTA) gives Companies House broad powers to set and update identity verification requirements.

• The Act itself doesn’t hard‑code the technical standards (e.g. whether biometrics are required). Instead, it delegates authority to Companies House to define and revise the process. To be clear, Companies House is therefore making the law here already, rather than Parliament.

2. Guidance vs. statute

• Current assurances — such as “no biometric sharing in the ACSP route” or “no copies of documents need to be submitted” — are written in guidance documents, not in the ECCTA 2023.

• Guidance can be updated quickly by Companies House or GOV.UK without parliamentary debate.

3. Mechanisms for change

• Policy updates: Companies House can issue new guidance requiring additional data elements (e.g. biometric checks for ACSPs).

• Framework changes: One Login is a federated authentication system. Its technical standards and data‑sharing agreements can be expanded across departments and made mandatory for any of the director verification routes chosen.

• MoUs (Memoranda of Understanding): Government departments can agree to share data under existing legal powers, without new legislation.

4. Scrutiny gap

• Because these changes are administrative rather than legislative, they can be fast, quiet, and under the radar of parliamentary scrutiny.

• Unless challenged (e.g. through judicial review), they don’t require a vote in Parliament.

Thank you for taking the time to read this article. It required over 20 hours of research and an additional 6 hours of writing, editing, and preparing the tables included. This is a complex subject, and I have done my best to simplify it and present it in plain English so that readers can better understand the risks involved and make informed decisions.

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