Three company directors were fined at City of London Magistrates' Court on 16 September. The one I keep coming back to is Marc Dillon, because he had already verified his own identity. He was convicted anyway, over what the other director on his board failed to do.
TL;DR: The first Insolvency Service prosecutions for identity verification offences include a director who had verified himself. He was convicted over his co-director's failure to verify. Section 1121 makes an officer liable where he fails to take all reasonable steps to prevent the breach. Your own verification is the easy half.
What actually happened at City of London Magistrates' Court?
These are the Insolvency Service's first prosecutions for identity verification offences under the Economic Crime and Corporate Transparency Act 2023 (GOV.UK, 2026).
Jill White of White (Reading Properties) Limited acted as a director without verifying, took part in board decisions and signed accounts. Modinat Banjo of J Isogony Apparel Limited signed and delivered accounts while unverified. Dillon, White's fellow director, had verified. He was convicted after failing to take reasonable steps to stop her continuing.
The money is beside the point. White was fined £166, Dillon £307 and Banjo £80, each with £85 costs plus surcharges of £66, £123 and £32. That's £1,029 between them, and Dillon, the one who did his own admin, paid most.
Why was a director who had verified convicted at all?
Because the duty runs two ways. Section 167M of the Companies Act 2006 bars an individual from acting as a director unless verified, and separately requires the company to ensure nobody does. Breaching that second limb is an offence by the company and by every officer in default (legislation.gov.uk, 2006).
"In default" is the part almost nobody has read. Section 1121(3) defines it as authorising or permitting the contravention, participating in it, or failing to take all reasonable steps to prevent it (legislation.gov.uk, 2006).
So the question I put to director clients is no longer "have you done yours?" It's "have you checked theirs, and what did you do when the answer was no?" Dillon knew the requirement existed. Knowing and doing nothing is what that third limb is built to catch.
How many director appointments are still unverified?
More than you would guess. Companies House management information puts director appointments at 55.33% verified as at 30 June 2026, up from 7.79% in December and 32.20% in March (Companies House, 2026). Real progress, but roughly 45% were still unverified with under five months of the transition year to run.
The figure that matters more for Dillon's fact pattern is individual PSCs, at 41.86% on the same date, some thirteen points behind directors.
The signal there is behavioural. People verify themselves reasonably well and don't chase the other names on the register, which is where the liability sits.
The two checks I run before a confirmation statement now
First, I sort the client list by company rather than by person, looking for any board where one director is verified and another is not. That mixed state is what got prosecuted, invisible if you track verification as a personal to-do list.
Second, I stopped treating a chased confirmation statement as a low-priority nag. All three defendants were also convicted over a late one, which tells you where these cases start: an ordinary filing default, not a fraud investigation. The statement is the trigger that surfaces an unverified director, and the real deadline is your own statement date, not the 18 November 2026 backstop everyone has written on a slide. Same instinct as reading the old accountant's files before I take a client on.
Verification is free through GOV.UK One Login, or via an authorised corporate service provider, who may charge (GOV.UK, 2026). If you use an agent, check they're still on the register, because a good number of ACSPs have been ceased or suspended. There's no opt-out; the step-by-step on director ID checks covers the mechanics.
Frequently Asked Questions
Can I be prosecuted if my co-director has not verified their identity?
Yes. Section 167M puts the duty on the company to ensure no unverified person acts as a director, and every officer in default commits an offence. Under section 1121(3) you're in default if you failed to take all reasonable steps to prevent it. That is what caught Dillon.
When does my company's identity verification deadline actually fall?
On your next confirmation statement date, not 18 November 2026. The transition runs twelve months from 18 November 2025, and each company is pulled in when its statement falls due.
Do I have to declare a Companies House conviction?
Yes, while it's unspent, though it probably won't reach a DBS certificate: section 167M carries a fine only in England and Wales, so it isn't a recordable offence. It's still a criminal conviction, and the rehabilitation period for a fine is twelve months from the date of conviction (GOV.UK, 2026). For that year it must be declared wherever unspent convictions are asked for, which covers a lot of finance applications and professional body declarations. The fine is small; the year of declaring it is the real cost.
If you want a second pair of eyes on which of your companies sit in that mixed state before the next confirmation statement, get in touch. I'm happy to run the register check with you.