Corporate law update: 19 - 25 September

This week:

• Three directors are fined in connection with failures to complete identity verification under the Companies Act 2006

• Other items of interest

First fines issued to directors for failing to verify their identity

The first fines have been issued to three directors of UK companies for failing to complete mandatory identity verification (IDV) under the Companies Act 2006.

IDV has been a requirement since 18 November 2025. The requirement applies to all persons (including existing directors) who are appointed to a new office of director, with a 12-month transitional period in place for individuals who were already directors of UK companies on 18 November 2025.

Mandatory IDV also applies to individuals who are members of a UK limited liability partnership (LLP), as well as to individuals who are persons with significant control over a UK company or UK LLP.

It is an offence for an individual to act as a director of a UK company (or a member of a UK LLP) if they have not completed IDV within the required timeframe.

One director was ordered to pay a total of £317 after taking part in board decisions and signing company accounts without having verified her identity.

A second director of the same company was ordered to pay a total of £515 because, although he had verified his own identity, he had not taken reasonable steps to ensure his co-director did so.

A third individual, who was a director of a different company, was ordered to pay a total of £197 after signing and delivering company accounts while unverified.

The fines are an indication that Companies House and the Insolvency Service (who are responsible for enforcing mandatory IDV) are taking the new requirements seriously. Although the acts of unverified directors remain valid, acting while unverified can lead to fines for both directors and the company itself and, in serious cases, may result in disqualification from acting as a director.

Read Companies House’s press release on the decision to fine three directors for failing to verify their identity

Other items

• Glass Lewis publishes season review. Proxy Advisor Glass Lewis has published its 2026 proxy season review for the UK. The review examines trends in publicly traded companies in the UK during the year and, where relevant, proxy advice. The review focuses in particular on executive remuneration, board gender balance, shareholder activism and virtual general meetings. Glass Lewis has also published its 2026 proxy review for Continental Europe.

  Read Glass Lewis’ 2026 proxy season review for the United Kingdom (opens PDF)

  Read Glass Lewis’ 2026 proxy season review for Continental Europe (opens PDF)

• EU simplifies CSRD requirements. The European Union has published the final version of two new delegated regulations relating to sustainability reporting standards under the EU Corporate Sustainability Reporting Directive (CSRD). The first regulation simplifies reporting for entities within the scope of CSRD. The second regulation sets out voluntary reporting standards for smaller companies outside the scope of CSRD and for smaller value chain partners. The new regulations apply to financial years beginning on or after 1 January 2027, but (broadly speaking) entities may adopt the new measures earlier on a voluntary basis.

  Access Commission Delegated Regulation (EU) 2026/1563, which simplifies reporting under the EU Corporate Sustainability Reporting Directive

  Access Commission Delegated Regulation (EU) 2026/1560, which introduces voluntary sustainability reporting standards for smaller companies