4 Transitional provision in connection with ID verification of existing directors

(1) This regulation applies in relation to an individual who became a director of a company before 18th November 2025.

(2) That company must deliver to the registrar an identity verification statement in respect of that individual at the same time as the company delivers its next confirmation statement during the transitional period.

(3) If the company fails to deliver a confirmation statement during the transitional period, the company must deliver to the registrar an identity verification statement in respect of the individual referred to in paragraph (1) at the same time as the company delivers its next confirmation statement.

(4) The duty—

(a) in paragraph (2) does not apply if the individual is not a director of the company at the time mentioned in that paragraph;

(b) in paragraph (3) does not apply if the individual is not a director of the company at the time mentioned in that paragraph.

(5) Section 853A(1)(b)(i) of the 2006 Act (duty to deliver confirmation statements) has effect as if it included a reference to the duties imposed by paragraphs (2) and (3).

(6) Where, on 18th November 2025, the delivery period within which the confirmation statement referred to in paragraph (2) is required to be delivered has yet to begin, or has already begun but is not yet expired, section 167M(1) of the 2006 Act (prohibition on director acting unless ID verified) does not apply to the individual, and section 167M(2) of the 2006 Act does not apply to the company with respect to that individual, until—

(a) the day after the day on which the company complies with the duty in section 853A(1); or

(b) if the company does not so comply, the day after the last day of the delivery period.

(7) Where, on 18th November 2025, the company has an overdue confirmation statement, section 167M(1) of the 2006 Act does not apply to the individual, and section 167M(2) of the 2006 Act does not apply to the company with respect to that individual, until the earlier of—

(a) the day after the day on which the company complies with paragraph (2); or

(b) the end of the day on 2nd December 2025.

(8) For the purposes of paragraph (7), the company has an overdue confirmation statement if it has failed to deliver a confirmation statement by the end of its last delivery period with an end date before 18th November 2025 and on 18th November 2025 the company has still not delivered that confirmation statement.

(9) In this regulation—

“delivery period” means the period mentioned in section 853A(1) of the 2006 Act;

“identity verification statement” means a statement in respect of an individual confirming that their identity is verified within the meaning of section 1110A of the 2006 Act (meaning of “identity is verified”);

“transitional period” means the period of 12 months beginning with 18th November 2025.