The Unverified Trustee: Week 1: Why Your Charity Could Be Breaking the Law (and You Don’t Even Know It)

🛑 STOP Being Stupid: Week 1 of 40.

Read time: 5 minutes

Right. Let’s not mess about.

There’s a new piece of mandatory compliance that’s about to land your charity in a proper mess if you ignore it. And I mean the kind of mess that makes accidentally double-booking the village hall look like a minor admin blip.

We’re talking about mandatory Identity Verification for Companies House.

Here’s the Thing About Being “Nice People”

The most spectacular form of charity stupidity? Believing that because you’re good people doing good work, you’re somehow exempt from the law.

You’re not.

The Economic Crime and Corporate Transparency Act 2023 (ECCTA—because we desperately need more acronyms) was designed to stop criminals setting up shell companies. But when the net drops, it catches everyone. And if you’re a company director, you’re in it.


Does This Actually Apply to You? (The Bit You Can’t Skip)

This identity verification is required for all Company Directors. Therefore:

  • IT APPLIES IF: Your charity is a Charitable Company Limited by Guarantee (or a Charitable Industrial and Provident Society). If so, your trustees are legally company directors and they must verify their identity. End of.
  • IT DOES NOT APPLY IF: Your charity is a Charitable Incorporated Organisation (CIO), a Trust, or an Unincorporated Association. Your trustees are safe… for now.

What Happens If You Ignore This?

From November 18, 2025, here’s the delightful reality for Charitable Companies that fail to comply:

  • New Appointments Stop Dead: You cannot appoint a new director until they’ve verified their ID. Full stop.
  • Existing Directors Get a Deadline: All current directors must verify before the company files its next Confirmation Statement after the deadline.
  • It Becomes a Criminal Offence: Yes. Criminal. For the individual unverified director AND the company.
  • Disqualification: Failure to comply can lead to fines, sanctions, and potentially being disqualified from acting as a director or trustee.

That’s right: your failure to spend 10 minutes with a passport could get you fined and disqualified. That’s world-class administrative stupidity right there.


The Actually Helpful Bit: Your 5-Step Action Plan

The deadline is November 18, 2025. Stop reading. Start acting.

  1. Check Your Status: Go to the Charity Commission register and check your Organisation Type. If it says ‘Charitable Company’, treat this like a fire drill.
  2. Gather Your ID: Each director needs ONE of these: Biometric Passport (any country) or a UK Photo Driving Licence.
  3. Use GOV.UK One Login: Each director/trustee verifies personally using the free GOV.UK One Login service. Start here: GOV.UK One Login for Companies House. It’s a one-off process.
  4. Get Your Code: Once verified, you get a unique 11-character Companies House personal code. This belongs to the person, not the company. Write it down. Keep it safe. Don’t lose it in a drawer with old birthday cards.
  5. Collect the Codes: Your charity secretary or filing officer needs to collect every trustee’s unique code. You’ll provide these when filing your next Confirmation Statement.

Stuck? Here’s Where to Get Help

I’m not a complete monster. If you or your trustees are struggling:

  • Support Phone: Call Companies House on 0303 1234 500 (select option 1 for One Login queries).
  • Alternative Route: Can’t verify online? Use an Authorised Corporate Service Provider (ACSP)accountants or solicitors can help (they’ll charge a fee).

The Art of Stupidity isn’t about ignoring problems until they explode. It’s about identifying the worst mistakes, fixing them before they blow up in your face, and maybe having a brew and a biscuit afterwards.

Start here. Start now. Your trustees will thank you. Your charity’s future self will definitely thank you.


Next Week: The ‘Trust Me’ Treasurer

Next Friday, we move from mandatory governance to internal risk, tackling a classic small-charity disaster: The ‘Trust Me’ Treasurer – Why One Person Should Never Control All the Cash.

Don’t miss a single step on your journey to administrative enlightenment (or at least, avoiding administrative catastrophe).

Subscribe to The Art of Stupidity – Real talk for people making change happen.

Got questions? Drop them in the comments. Got a stupid mistake you’ve made? Even better—we all learn from the messy middle.

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