If a director cannot complete identity verification in time and the confirmation statement (CS01) goes overdue, Companies House will not accept the filing until the identity verification statement is provided. There is one step you can take through Companies House to ask for enforcement action to be paused: making a representation.

Why is the confirmation statement blocked?

Each director must have verified their identity with Companies House, and the confirmation statement cannot be filed without the director's identity verification information. Inform Direct cannot verify a director's identity for Companies House and is not an authorised corporate service provider (ACSP). The director can verify directly with Companies House, or an accountant or other ACSP can verify them. See How to add a Companies House personal code for a Director or PSC on Inform Direct?

The best way to protect the company is to get the director verified as soon as possible and then file the confirmation statement. A representation does not remove the requirement to verify.

What is a representation?

A representation is a written request to Companies House to consider exceptional circumstances before it takes enforcement action over an overdue filing. Companies House has a GOV.UK form for this: Make a representation for not filing an identity verification statement. It can be used for:

• an overdue confirmation statement and director identity verification statements; or
• an overdue identity verification statement for a person with significant control (PSC).

When can I make one?

• Only after you have received a letter from Companies House telling you the filing is overdue (a default letter). A representation made before this will be rejected.
• Within 28 days of the date on the default letter. Companies House will not consider a representation received after that.

What happens next?

Companies House will write to tell you whether it accepts the representation, and its decision is final. It is likely to accept where there is evidence of exceptional circumstances connected to the due date and where it would be disproportionate to pursue enforcement at that time (for example, a serious IT failure when the statement was due with no other way to complete it). If it accepts, it will pause enforcement action, usually for up to 2 months, to give the company time to comply. After that, Companies House may pursue enforcement without further notice, which can include financial penalties, prosecution and removing a defaulting company from the register.

A representation is therefore a short pause, not a way of avoiding identity verification, and it is not guaranteed to be accepted. Inform Direct cannot submit a representation for you: it is made by the company or its agent on the GOV.UK form.

Is there anything different for a PSC?

For a PSC, Companies House has discretion to extend the identity verification due date by up to 14 days, using a separate GOV.UK request form. This applies to PSCs only. See Request to extend the identity verification deadline for a person with significant control (PSC). If a person has died or is seriously ill or incapacitated, see What Happens if a PSC Cannot Complete Identity Verification (Death, Serious Illness, or Incapacity)?

What if the company is already facing strike-off?

If Companies House has started a compulsory strike-off because the confirmation statement is overdue, it is stopped by filing the overdue confirmation statement before the notice period ends. See Can I stop or restore a Company in the Process of Being Struck Off? For the Companies House approach to non-compliance, see Companies House approach to non-compliance with mandatory identity verification.

This is general guidance, not legal advice - confirm with a solicitor if unsure.

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