Published: 28 October 2025 11:06 am  Author: Oliver Stanley

IDV filing deadlines for PSCs who are also directors or LLP Members – IMPORTANT!

 

Companies House has just released an update to the rules around when PSCs who are also directors or LLP members need to file their UIDs at Companies House (i.e. confirm that they have completed IDV).  We have written quite a lot about this already (e.g. see here), but the rules have now changed.

 

What has changed and what are the rules?
Where a PSC is also a director or LLP member of an existing entity, that PSC no longer has a deadline of 14 days from the confirmation statement date to file their UID, but now has a 14 day window to file this information.  There are a few key points to understand about this:

(1) the 14 day window starts the day after the end of the confirmation statement review period (aka the confirmation statement date) as set on 18 November 2025.  Therefore, if a company’s confirmation statement date is 31 March 2026, then the window for filing the PSC UID runs from 1-14 April 2026.

(2) This window is ‘locked’ by reference to what the confirmation statement date is as of 18 November 2025.  If an entity files a confirmation statement early, that does not change the window – i.e. it won’t start the 14 day period for the PSC to file their UID.  It will remain as it was as of 18 November 2025.  So, in the example above, if a company chooses to file its confirmation statement in January 2026 and it has PSCs who are also directors, they will still only be able to submit their UID in the period 1-14 April 2026.

(3) Because there is a filing ‘window’ for PSCs in this category, you cannot file UIDs for PSC directors or PSC members ahead of time.  You have to wait until the window opens.

(4) The window dates will be made available by Companies House, we believe, on the public register.

Kudocs is already adjusting our system to accommodate these changes to make it as easy as possible for our customers to understand the deadlines and windows and file the right information at the right time, but this does really seem very complicated!

 

What happens if the PSC is just a PSC?  For these individuals, the rules remain the same – the PSC has  to file their UID within 14 days of the start of their birth month.  This is a deadline, not a window, so they can file before that date.

 

Does this affect when a director or LLP member needs to file their UID? No – the rules remain the same – they have to file their UID at the same time as filing the confirmation statement.  This is a deadline, not a window, so they can file before that date if the company files a confirmation statement early.  Please note that whenever an entity files its first confirmation statement date after 18 November 2025, it will need to include all the mandatory UIDs at that time.  Even if the confirmation statement is being filed early, the filing will be rejected unless all the UIDs are provided.  In case you were thinking of filing a few confirmation statements with a few UIDs in each – you wont be able to!

 

Does this affect incorporations?  No – the rules around providing PSC UIDs when incorporating after 18 November will remain unchanged.