This guide draws on expert insights from Steve Lamb (CEO, Kyckr), Ray Blake (Dark Money Files), and Vasco Vaz (CEO, Dotfile) to reveal what automated checks miss and how compliance professionals can navigate persistent data quality challenges. Watch the full webinar UK Companies House: Signals, Gaps, Actions.
What Changed with Companies House Identity Verification
The November 2025 Verification Requirements
From November 18, 2025, all new company directors must verify their identity before incorporation or appointment. Existing directors have until November 2026 to comply - creating a 5.5 million company backlog that means legacy data quality issues will persist for years.
Ray Blake, co-host of the Dark Money Files podcast, offers a reality check: "Don't get too excited about Companies House verification. We've done identity verification in banking for decades, and criminals still get through. This just closes the gaping window."
With basic verification standards and no mandatory liveness detection, sophisticated fraudsters using AI-generated documents can still circumvent checks. The real challenge? In the age of AI, flat document verification without biometric checks remains vulnerable.
Companies House Strengths: Why It's Still World-Class
Before diving into data quality issues, it's important to recognize what makes Companies House exceptional among global corporate registries.
Free Access and Transparency
Since June 22, 2015, all Companies House public data became completely free. The register was accessed 16.5 billion times in 2023-2024 - up from 1.3 billion in 2015-2016. This accessibility marks it out globally, where many registries charge significant fees per search.
Public Beneficial Ownership Data
The UK remains the only major economy with a fully public Persons of Significant Control (PSC) register. Following European Court of Justice rulings, most EU countries rolled back public UBO access, requiring "legitimate interest" frameworks that create barriers for compliance teams.
Steve Lamb, CEO of Kyckr says: "The fact that there is still a public UBO register in 2025 in a major global economy marks it out significantly. Companies House is very modern with excellent data transparency and availability."
Active Fintech Engagement
Companies House actively solicits feedback from the fintech community through surveys and roundtables - rare globally among corporate registries. This engagement demonstrates recognition that obliged entities are key stakeholders in registry reforms.
Critical Data Quality Issues That Basic Checks Miss
1. Companies Listed as Ultimate Beneficial Owners
Despite FATF standards requiring UBOs to be natural persons, companies are routinely filed as Persons of Significant Control on Companies House records.
Real-world example: Inova Medical, a major COVID contract beneficiary, listed its chief legal officer as the PSC rather than identifying the actual beneficial owner of parent company Persaca Capital. When Private Eye questioned this, the spokesperson stated "the identity of its shareholders is private" - fundamentally misunderstanding that the PSC register exists to make beneficial ownership transparent.
Compliance requirement: UK regulations explicitly prohibit using the PSC register as your sole UBO identificationsource. You must verify what your customer declares against what Companies House shows - and investigate discrepancies.
2. Fictitious Officers and Identity Theft
Ray Blake uncovered a company called "Telif AG Limited", a UK entity registered to mimic Telif AG, the legitimate Swiss commodities trader with $4.8 billion in annual sales.
The setup:
- UK company name: "Telif AG Limited" (using foreign suffix AG + UK suffix Limited)
- Listed director/PSC: Jordan Walker Toft (allegedly Australian, residing in England)
- Reality: The only Jordan Walker Toft with Australian nationality is an executive chef in Sydney with no connection to the company
Fraud vector: Invoice redirection fraud - the UK entity intercepts payments meant for the legitimate Swiss company by inserting itself into supply chains.
Detection strategy: When reviewing Companies House data, search globally for similar company names, especially those using foreign legal entity suffixes (AG, GmbH, SA, SpA) alongside UK suffixes.
3. Student Accommodation Fraud Patterns
Blake identified systematic bulk incorporations at Sheffield student housing:
- Flat B315, Bailey Fields: Mi Mac Limited
- Flat B316, Bailey Fields: Different company
- Flat B317, Bailey Fields: Another company
All incorporated within days, each with different Portuguese directors (born 1996-1998).
Why student housing works for fraudsters: Students ignore official mail. When Companies House sends mandatory address confirmation letters, typical residents would report suspicious registrations. Students simply discard letters unopened, allowing fraudulent addresses to persist.
Compliance red flag: Multiple companies at residential addresses, especially student accommodation, should trigger enhanced due diligence in your KYB process.
4. Hidden Director History Patterns
Basic Companies House verification won't reveal that a director has previously established 25 companies, all struck off before filing accounts - a clear pattern indicating systematic fraud or phoenixing.
Similarly, contextual analysis would show that the same week your target company incorporated, 50 companies with identical Standard Industry Classification (SIC) codes were registered at different properties on the same residential street, indicating coordinated company formation agent activity potentially linked to fraud.
Advanced Due Diligence Techniques
Ray Blake: "It's very easy to use Companies House data to meet your legal KYB obligations. But that leaves unexploited enormous amounts of data that can reveal if the UBO has set up 25 companies all struck off before filing accounts."
Address Clustering Analysis
Use Companies House advanced search facility to:
- Find all companies registered at a specific address
- Investigate building type (office block, residential, virtual office)
- Identify suspicious clustering patterns
- Cross-reference with Google Street View to verify premises
Sequential Company Number Investigation
Blake's technique: "Look at consecutive company registration numbers - the couple that went in before and after the one you're investigating. Companies with sequential numbers often come from the same formation agent."
Example: Company 12345678 incorporated the same day as 12345677 and 12345679 -investigate all three for patterns.
Director History Deep-Dive
Beyond current appointments:
- How many companies has this director previously established?
- How many were struck off without filing accounts?
- Are there patterns of serial company formation?
- Does the director appear on multiple unrelated businesses?
Copycat Name Screening
Search globally for:
- Similar company names in other jurisdictions
- Use of foreign suffixes causing confusion
- Companies potentially mimicking legitimate businesses
Ray Blake's golden rule: "Does this look right? Does this make sense bearing in mind everything else I know? Use your compliance instincts."
Best Practices for Companies House Verification
1. Multi-Source Verification (Legally Required)
UK law explicitly prohibits relying solely on the PSC register for UBO identification. You must verify customer declarations against Companies House data and other sources.
Required verification layers:
- Companies House PSC register
- Customer declarations and supporting documents
- International business registries (for cross-border ownership structures)
- Corporate structure charts from the customer
- Verification of controllers not meeting PSC thresholds
2. Implement Contextual Intelligence
Go beyond basic data extraction:
3. Layer Additional Data Sources
Companies House should be one component of comprehensive due diligence:
CIFAS: Fraud flags shared among UK financial institutions - critical for identifying directors or companies with fraud history
Sanctions and PEP screening: Entity and individual-level screening against global watchlists
Adverse media monitoring: Reputational risks not captured in official registers
Credit bureau data: Financial stability indicators, county court judgments, payment history
International registries: For cross-border ownership and ultimate parent verification
4. Ongoing Monitoring
Static verification isn't enough. Establish monitoring triggered by:
High-risk changes:
- Beneficial ownership modifications
- New director or PSC appointments
- Registered address changes
- Company name changes
- Missed filing deadlines
This approach ensures business relationships remain compliant throughout their lifecycle.
How Companies House Compares Internationally
Key insight: Companies House excels in accessibility but historically lagged in verification. Denmark demonstrates that comprehensive verification significantly improves data quality despite higher costs.
Coverage Gaps: What Companies House Doesn't Include
Sole traders: No registration requirement exists. Verify via VAT registration, self-assessment tax records, or professional body memberships.
Charities: Registered with the Charity Commission (separate registry with free API access).
Partnerships: Some register with Companies House (LLPs must); general partnerships don't require registration.
Comprehensive UK business verification requires integrating multiple registries beyond Companies House alone.
How AI is Transforming Companies House Verification
Steve Lamb claims "AI can help orchestrate additional sources and perform contextual checks, meaning we can do better checks, be more compliant, but also keep the economic system moving."
Modern KYB platforms leverage AI for:
Document intelligence: Extract shareholder data from Companies House filings (confirmation statements, incorporation documents) where structured API data isn't available
Pattern recognition: Identify fraud indicators across millions of director histories, address clusters, and formation patterns
Ownership structure mapping: Automatically trace complex corporate hierarchies across jurisdictions
Risk scoring: Aggregate hundreds of factors simultaneously for intelligent assessment
Continuous monitoring: Track Companies House changes with smart alerting for material modifications
The ECTA Transformation: Beyond Identity Verification
The Economic Crime and Corporate Transparency Act (ECTA) 2023 represents the most significant UK company law reform in decades.
Enhanced Companies House powers:
- Query and reject suspicious filings
- Investigate anomalies before publication
- Share intelligence with law enforcement
- Impose penalties for false information
New criminal offenses:
- Providing false information to Companies House
- Failure to comply with verification requirements
- Facilitating economic crime through corporate structures
How Dotfile Streamlines Companies House Verification
Dotfile automates comprehensive business verification across Companies House and 200+ global registries with contextual intelligence that identifies fraud patterns automated checks miss.
Our platform delivers:
- Companies House integration enabling address verification and analysis
- Automated UBO verification resolving PSC register gaps through multi-source enrichment
- Sanctions and PEP screening at entity and individual levels
- Multi-factor risk scoring combining multiple data sources
- Ongoing monitoring with smart alerting for material changes
- 90% faster onboarding while enhancing compliance effectiveness
By combining Companies House data with global registries, document verification, and contextual intelligence, Dotfile transforms business verification from a compliance burden into a competitive advantage.
Companies House offers world-class accessibility and transparency, with improving verification under ECTA reforms. However, compliance professionals must understand persistent data quality limitations and implement sophisticated, multi-layered verification processes.
Ray Blake says: "Between imperfect data that's fully transparent and perfect data nobody can see, I'd always choose the former, it can be challenged and improved."
The path forward
Use Companies House as your starting point, not your endpoint. Layer contextual intelligence, multiple data sources, and professional judgment asking "does this make sense?"
As corporate registries evolve from librarians to gatekeepers, understanding both capabilities and limitations isn't just about regulatory compliance, it's about protecting your organization from financial crime while maintaining trust in the global economy.
Want to learn more about Companies House? Watch the full webinar.
