First directors fined for skipping Companies House ID checks

The cases

Source: Insolvency Service and Companies House, 17 September 2026.

Jill White and Marc Dillon, directors of White (Reading Properties) Limited, company number 00722126, and Modinat Banjo, director of J Isogony Apparel Limited, company number 09299408, were fined at City of London Magistrates' Court on Wednesday 16 September 2026. The Insolvency Service and Companies House confirmed the outcome in a press release dated 17 September 2026. These were the first court actions for identity verification offences under the Economic Crime and Corporate Transparency Act 2023, and the facts of each case set out what the enforcement bodies treated as the conduct that mattered.

White, 62, acted as a company director despite not verifying her identity. She participated in board-level decision making and signed company accounts while unverified, and completed verification in early September 2026, around nine months after the deadline. Dillon, 62, had verified his own identity but was prosecuted after failing to take reasonable steps to prevent White from continuing to act as a director while unverified. Banjo, 50, continued acting as a director and signed and delivered company accounts while unverified, completing identity verification on or around 28 May 2026. All three were also convicted after their companies failed to file a confirmation statement within the statutory period.

The fines

White was fined 166 pounds, ordered to pay costs of 85 pounds and a victim surcharge of 66 pounds. Dillon was fined 307 pounds with costs of 85 pounds and a surcharge of 123 pounds. Banjo was fined 80 pounds with costs of 85 pounds and a surcharge of 32 pounds. The amounts are small in the context of criminal convictions, and the totals vary mainly because of how fines and surcharges are calculated rather than because the underlying failures were treated as materially different in kind.

The conviction is the point. Each director now has a criminal record for offences connected to identity verification and to the late filing of a confirmation statement. The financial penalty is modest, but the finding of guilt is not, and it follows a process in which the Insolvency Service states that multiple opportunities were provided to comply before enforcement action was taken. For directors who assume that a missed verification step is an administrative matter to be tidied up later, these three outcomes show the opposite: the failure was prosecuted, and the accompanying confirmation statement failure was prosecuted alongside it.

What the law requires

Identity verification is a central part of the Economic Crime and Corporate Transparency Act 2023. Newly appointed directors have been required to verify their identity with Companies House before acting as a director from 18 November 2025. Existing directors are required to verify during the 12-month transition period, when filing the company's next confirmation statement. The confirmation statement is therefore not merely a routine annual filing; for an existing director it is the trigger point at which verification is expected to be completed.

Identity verification can be completed online through Companies House free of charge or via an Authorised Corporate Service Provider. The requirement applies to directors, and the enforcement position set out by the Insolvency Service is that there is no option to opt out. Daniel Hart, Senior Criminal Lawyer at the Insolvency Service, said: 'There is no option to opt out. Directors who continue to act without verifying their identity risk investigation and prosecution.' He adds that multiple opportunities were provided to comply before enforcement action. Martin Swain, Director of Intelligence and Law Enforcement Engagement at Companies House, said: 'These cases send a clear message that identity verification is not optional.'

The part directors miss

Dillon's case is the warning worth reading twice. He had verified his own identity and was still prosecuted, because a director has a duty to ensure the company does not allow an unverified person to keep acting as a director. The charge was not that he failed to verify himself. It was that he failed to take reasonable steps to prevent White from continuing to act while unverified. A director who has completed verification can therefore still face prosecution if another director on the same board has not, and if the verified director does nothing about it.

That shifts the practical question from an individual checklist to a board-level one. The Insolvency Service position is that there is no option to opt out, and that multiple opportunities to comply were given before enforcement. Companies House expects the vast majority to comply, while stating that enforcement will follow where they do not. The two messages sit together: compliance is expected to be near universal, and the small minority who do not comply should expect the same route to court that produced these three convictions.

What to do now

Check whether every director and person with significant control has verified, not just yourself. Confirm the date of the next confirmation statement, since that is the trigger for existing directors to verify during the 12-month transition period. Verification is free and done online with photo ID, or through an Authorised Corporate Service Provider. Where a director has not verified, the verified directors should consider what reasonable steps they are taking, because Dillon's prosecution turned on exactly that question rather than on his own verification status.

A late confirmation statement is a separate offence, and both charges appeared together in all three of these cases. That combination matters for planning: the confirmation statement deadline is not only about keeping the register up to date, it is also the point at which existing directors are expected to have verified. The first prosecutions produced fines of 166 pounds, 307 pounds and 80 pounds, with costs of 85 pounds in each case and victim surcharges of 66 pounds, 123 pounds and 32 pounds. The sums are small. The convictions, and the fact that they are now on record, are the part that lasts.

Related coverage on Kael Tripton: Before you order a certified document from Companies House: costs, options and the free alternative, Best Accounting Software for Companies House Filing 2028: Digital Submission Compared, Director Mortgage UK 2026: How Limited Company Directors Are Assessed for Mortgages, Dividend vs Salary UK 2026: Most Tax-Efficient Split for Company Directors, Sole trader vs limited company: how your insurance needs and personal liability change.

Frequently asked questions

When did the first prosecutions for identity verification offences take place?

The first court action for identity verification offences resulted in three directors being fined at City of London Magistrates' Court on Wednesday 16 September 2026, confirmed in an Insolvency Service and Companies House press release dated 17 September 2026.

Who was prosecuted and what were they fined?

Jill White and Marc Dillon, directors of White (Reading Properties) Limited, and Modinat Banjo, director of J Isogony Apparel Limited. White was fined 166 pounds with 85 pounds costs and a 66 pound victim surcharge; Dillon was fined 307 pounds with 85 pounds costs and a 123 pound surcharge; Banjo was fined 80 pounds with 85 pounds costs and a 32 pound surcharge.

Why was Marc Dillon prosecuted if he had verified his own identity?

Dillon had verified his own identity but was prosecuted after failing to take reasonable steps to prevent White from continuing to act as a director while unverified. The duty extends to preventing an unverified person from continuing to act.

When must newly appointed and existing directors verify their identity?

Newly appointed directors have had to verify with Companies House before acting as a director since 18 November 2025. Existing directors must verify during the 12-month transition period, when filing the company's next confirmation statement.

How is identity verification completed and what does it cost?

Identity verification can be completed online through Companies House free of charge or via an Authorised Corporate Service Provider.