Challenge: try running a business in the UK without submitting yourself to a Biometric Face Match aka Digital ID.
The UK Government recently announced that it intends to mandate a Digital ID for all adult UK citizens, without which they will not be able to work.
This is almost already the case for UK business owners.
Try opening a business bank account without a Biometric Face Match.
What is a Biometric Face Match?
What is a Biometric Face Match?
"Biometric technology has become a gold standard of identification. During the user journey, clients are required to capture a ‘selfie’.
Sophisticated software then uses 68 facial landmarks to extract the facial features. The algorithm recognises natural changes between the ID image and the video image to authenticate identity via a liveliness test.
The Biometric Face Match check will determine that the person undergoing the identification process is the legitimate holder of the provided identity document verification.
The portrait photo is extracted from the uploaded identity document for the biometric face match. The advanced facial recognition algorithms, it analyses and compares the facial features in the live selfie with those in the document photo. The system calculates a score based on the confidence of the match. If the score passes the required threshold, the check will pass.
If an e-passport is used, the chip photo will be extracted using NFC (Near Field Communication) technology. This provides a gold standard of verification as the chip photo, portrait photo and selfie photo are all cross-validated as part of the check."
Source: Verify by Tiller - Know Your Customer (KYC) checks made simple
Try purchasing business premises without a Biometric Face Match.
Try returning to the UK from an overseas business trip without a Biometric Face Match.
Try even popping to the shop for a bite to eat a Biometric Face Match!
Read more: Are facial recognition cameras in shops a step too far? (BBC 24 Oct 2025)
Read more: BBC Newsnight Report (26 May 2024)
And from November 2025, try submitting your annual Confirmation Statement (CSO1) to Company's House without a Biometric Face Match.
What prompted this post?
The Economic Crime and Corporate Transparency Act 2023, which makes digital identity verification (Digital ID) a new legal requirement for company directors and Persons of Significant Control (PSC) from November 2025.
From November 2025, all company directors and PSCs of companies listed at Companies House will be mandated to:
- first, register for a GOV.UK One Login Account, and
- next, provide Companies House with a Biometric Face Match.
Not happy with having to do this?
No worries.
You can instead confirm your identity using the services of a so-called Authorised Corporate Services Provider (ACSP) aka Companies House Authorised Agent.
Mmmm.
I tried to find one just now and none yet appear to exist
Companies House are apparently preparing a list, but I cannot find it.
Accountants and solicitors seem to be the most likely candidates to offer the services of an Authorised Agent, and yet a cursory search of forums indicates a reluctance on their part. Wonder why?
But what if they were keen as mustard to take your money and act on your behalf?
What else would they ask you to provide?
A Biometric Face Match.
Consequences
Will this be the proverbial 'straw that breaks the camel's back'?
I know of at least one small business owner having decided to return to being a sole trader simply because of the wish to avoid Big Brother creep.
They may rue this decision if their turnover meets the HMRC requirements for mandatory quarterly tax returns.
HMRC Guidance: Check if you are eligible for Making Tax Digital for Income Tax
The ever increasing plethora of rules and regulations imposed upon UK small businesses in recent years must surely have a debilitating impact on their performance and growth prospects.
What will happen if you do not comply with the new verification requirements?
"Any director who continues to act without verifying their identity will be committing an offence. The company is also committing an offence if they fail to rectify this.
If you do not comply with the verification requirements, Companies House may take enforcement action. This may include prosecution and financial penalties for the company and its directors.
The company and its directors may also be committing an offence for failing to file a confirmation statement."
Source: Companies House email dated 7 October 2025.
Subject: One month to go – identity verification becomes a requirement from 18 November 2025.
Learn more
Video: Understanding identity verification for Companies House
Guidance When you need to verify your identity for Companies House
Guidance: Verify your identity for Companies House
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Ken Edwards - Company Founder
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