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ARTICLE · 13 OCTOBER 2025

Pension Scheme Trustee Directors – Identity Verification Requirements

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On 18 November 2025, a requirement will come into force for individual directors of UK companies to verify their identity. This requirement will apply to individual directors of all UK companies...

United KingdomEmployment and HR
Giles Bywater
Giles Bywater
Katherine Carter
Katherine Carter
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On 18 November 2025, a requirement will come into force for individual directors of UK companies to verify their identity. This requirement will apply to individual directors of all UK companies – including directors of a company which has been appointed as the trustee of an occupational pension scheme (referred to in this update as "trustee directors" of a "trustee company").

What are the identity verification requirements?

Under the Economic Crime and Corporate Transparency Act 2023 (the "Act"), individuals will be prohibited from acting as a company director unless their identity has been verified and companies will be under an obligation to ensure that individuals do not act as a director unless their identity has been verified. A director's appointment must also be notified to Companies House within 14 days and, if notice is not given within that period, the director will be prohibited from continuing to act as a director until notice has been given. Breach

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