Corporate law update: 1 - 7 November 2025

This week:

• Identity verification hits one million people in advance of mandatory IDV coming into force on 18 November 2025
• Legislation is published to require large companies to report on their performance in paying supplier invoices in their annual report
• Other items this week

Identity verification hits one million people, as Companies House launches further routes to verify

Companies House has reported that more than one million individuals have now verified their identity, in advance of mandatory identity verification (IDV) coming into force this month.

From 18 November 2025, all new company directors, LLP members and registrable persons with significant control (PSC) will be required to verify their identity. Individuals already in one or more of these roles will have a transitional period in which to do so.

However, it has been possible since the beginning of 2025 to verify one’s identity in advance of the commencement of mandatory IDV. This can be completed directly with Companies House through one of three routes, or alternatively through an authorised corporate service provider (ACSP).

In addition, Companies House has expanded its online service to allow individuals who live in the UK to check whether they can verify their identity without photographic ID. The service will inform an individual whether they can complete IDV with their bank or building society details and National Insurance number, or alternatively in person at the Post Office.

Read Companies House's announcement that one million people have verified their identity

Access Companies House’s updated guidance on verifying your identity with Companies House

Legislation published to require payment practice reporting in annual reports

Regulations have been published which will require large companies to publish information on their invoice payment practices in their annual report.

The Government previously published draft regulations in July 2025. The final regulations are unchanged from that draft.

The legislation follows a commitment by the Government in its Modern Industrial Strategy, published in June 2025. You can read more about the UK’s Modern Industrial Strategy in our separate piece.

The new regulations replicate in part the UK’s existing payment practices reporting regime (PPRR). Under the PPRR, large UK companies must publish a half-yearly report setting out their practice for paying supplier invoices, as well as statistics for payment of invoices over the preceding year, in a separate payment practices reporting portal.

The new duty to include metrics in the annual report also applies only to large UK companies.

Reporting will begin for a company’s first financial year falling on or after 1 January 2026.

Under the new regulations, companies must disclose the following information in their directors’ report:

• the average number of days taken to pay invoices;
• the percentage of invoices and sum total paid within the first 30 days, between 31 and 60 days, and after 60 days from receipt of invoice; and
• the percentage of invoices and sum total that were not paid during the applicable payment period.

Companies are not required to include other information currently published under the PPRR.

The new regulations do not amend or revoke the existing PPRR. Large companies will continue to be required to report the full gamut of information under the PPRR every six months through the Government’s payment practices reporting portal.

However, alongside this, the new regulations mean that companies will need to publish a portion of this information in their annual report. Given the reporting periods are aligned, this should hopefully be a case of listing the relevant information and placing it into the annual report.

Access the Companies (Directors’ Report) (Payment Reporting) Regulations 2025 (opens PDF)

Other items this week

• FRC updates Corporate Governance Code guidance on non-executive remuneration. The Financial Reporting Council (FRC) has published an updated version of its guidance on the UK Corporate Governance Code. The updated guidance provides more commentary on remuneration for non-executive directors, particularly in relation to share awards and performance-related remuneration.

Access the FRC’s updated guidance on the UK Corporate Governance Code

• ISS launches 2026 benchmark policy open comment period. Institutional Shareholder Services (ISS) has launched an open comment period for its global benchmark policy for 2026. The core topic of focus for the UK is what amounts to an “in-person” general meeting, as ISS looks to address the practice of more restrictive in-person shareholder meetings which have the potential to diminish shareholder participation or restrict opportunities for board engagement. The survey closes on 11 November 2025.

Access ISS’s proposed benchmark policy changes for 2026 (opens PDF)

• FRC publishes new Stewardship Code guidance. The Financial Reporting Council (FRC) has published guidance to accompany the 2026 version of its Stewardship Code, which it published in June 2025. The Stewardship Code sets out what the FRC considers best practice for institutional asset owners and asset managers when exercising their stewardship responsibilities. Like the FRC’s UK Corporate Governance Code, it operates on a “comply or explain” basis. The new guidance is designed to assist organisations with reporting under the Stewardship Code.

Access the FRC’s new guidance on the Stewardship Code 2026