ID verification for golf clubs

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Companies House are in the process of implementing some significant changes coming from the Economic Crime and Corporate Transparency Act.

These changes are designed to make UK company records more trustworthy and to stop fraud.

Becoming fully mandatory for Confirmation Statements due from 18 November 2025 onwards, Companies House is introducing a new system to make sure that every person connected with a company is who they say they are. The rules apply to all companies, including golf clubs that are set up as companies limited by guarantee, as well as any other businesses or organisations where directors, committee members, or controlling parties change regularly.

The main point is simple: every company director and every person who owns or controls a company (often called a person with significant control, or PSC) will need to prove their identity to Companies House. Without all the PSC’s and directors being verified, Companies House will not allow certain filings to be made, including the confirmation statement. If a confirmation statement is not done, the company will eventually go under compulsory dissolution with any remaining assets going to the Crown. Golf clubs, which often have committees where members rotate through officer roles like treasurer, secretary, and chair annually will need to pay particular attention to these new rules, as each new director will have to go through the identity check process before they can legally act in their role.

So how does the verification actually work? There are two ways to do it. The first is by going directly through Companies House, which will be done online. The person will need to upload a valid ID, such as a passport or driving licence, and then take a selfie photo or video to confirm they match the ID. Companies House will then check the details, confirm that the person is genuine, and issue them with a unique ID number. That number will be linked to all of their dealings with Companies House going forward. The second way is to go through what’s called an Authorised Corporate Service Provider (ACSP), which might be the golf club’s accountant, solicitor, or a company formation agent. These service providers are already used to doing identity checks as part of their anti-money-laundering obligations, so they can verify the person and then notify Companies House on their behalf. For clubs that work closely with accountants or administrators, this second route might be easier, especially if several committee members need to be verified at the same time.

For golf clubs, this new process will change how they bring new committee members on board. Many golf clubs are incorporated as companies limited by guarantee, meaning they don’t have shareholders but instead have members, with a committee or board of directors overseeing the club’s operations. These directors often rotate every year or two, particularly roles like treasurer or captain. Under the new rules, every time someone is appointed as a director, they must complete identity verification before they can officially take up their role. If they don’t do it, they simply cannot act as a director, even on a temporary basis. That could cause problems if, for example, the club needs to file its annual confirmation statement or submit accounts but the people responsible for authorising the filings haven’t been verified.

The timeline is also important. For new clubs being formed, no director or PSC can be appointed without first proving their identity. For existing clubs and companies, there will be a transition period, starting on 18 November 2025, during which all directors, PSCs, and anyone filing on behalf of the company must complete the process. Once that period ends, anyone not verified will not be allowed to continue in their position, and the club could be flagged as non-compliant with Companies House. That might mean filings get rejected, fines or penalties are issued, and in the worse case result in the company being dissolved.

One of the big headaches for golf clubs is the sheer frequency with which committee members change. While a commercial business might have the same directors for many years, golf clubs often elect new captains, treasurers, or secretaries every year. That means the club will constantly need to ensure that new committee members go through the verification process as soon as they’re elected, so they can legally act on behalf of the club. Without planning, it’s easy to imagine a situation where a club can’t submit its accounts on time because its new treasurer hasn’t completed verification, or where a new captain isn’t legally recognised as a director because their ID hasn’t been confirmed. Clubs will need to build this process into their annual handover or induction procedures, just like they do with bank mandates or access to club management systems.

The process itself isn’t especially complicated, but it does require individuals to have the right documents and be comfortable with online systems. Most people will use a passport or driving licence and complete the selfie video process on a phone or computer. For committee members who aren’t tech-savvy, the club might need to help them through the process or ask their accountant or solicitor to handle it as an authorised service provider. In some cases, this might even mean building in a small administrative cost each year for new directors, especially if the club prefers to have their accountant handle the verification rather than asking volunteers to do it themselves.

The easiest way for a golf club to handle all of this is to make identity verification part of its normal procedures. When someone is elected or appointed as a committee member or director, they should be told immediately that they need to complete the Companies House ID check before they can officially act. The club could provide instructions for doing it online or through their accountant and follow up to make sure it’s done quickly. By making it a standard part of the handover process, the club can avoid problems later, like rejected filings or gaps in its director list.

While these new rules might feel like extra bureaucracy, the government’s goal is to stop fraudulent or fake companies from operating and to make it easier for people to trust company records. For most golf clubs, the main challenge will be getting used to the process and making sure new committee members don’t get caught out by the requirement. With a little planning, the impact should be manageable, but clubs that rely heavily on volunteers and have frequent turnover in their director roles will need to be proactive to avoid problems.

Do you need extra information?

Ravi Juthani - Principal at Hillier Hopkins

Ravi went into accountancy in 2013 following a time working in investments, going on to become a qualified accountant and tax advisor.

Contact Ravi at ravi.juthani@hhllp.co.uk or on +44 (0)1923 634255

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