By
August 24, 2026
Do All Directors and Shareholders Need to Complete KYC?
Not necessarily. When a UK limited company applies for a business bank account or payment service, the provider needs to verify the company and identify relevant people behind it. However, this does not automatically mean every director and every shareholder will undergo exactly the same individual KYC process.
The provider will normally focus on beneficial owners, people who control the company, people authorised to operate the account, and other individuals it considers necessary under its risk-based procedures. UK customer due diligence rules require beneficial owners to be identified and reasonable measures taken to verify their identities.
A financial provider will normally collect information about the company's directors. For a corporate customer, UK due diligence requirements include taking reasonable measures to determine and verify the full names of the board of directors and senior persons responsible for the company's operations.
However, whether every director must personally complete identity verification can depend on the provider and circumstances.
A provider may particularly require verification from directors who:
Anyone acting on behalf of the customer must also be identified and verified, with their authority to act established.
Not necessarily.
The key issue is often whether a shareholder qualifies as a beneficial owner.
Under UK AML guidance for a body corporate, an individual holding more than 25% of the shares is an example of a beneficial owner. A person may also qualify through voting rights or other significant influence or control.
For example:
Shareholder A – 60%
Likely a beneficial owner and therefore likely to require identification and verification.
Shareholder B – 30%
Also above the more-than-25% threshold and likely to be treated as a beneficial owner.
Shareholder C – 10%
Would not qualify as a beneficial owner merely because of that 10% shareholding, although the provider may still collect information about them or require additional checks depending on the circumstances.
For the beneficial-owner test described in HMRC's AML guidance, the shareholding threshold is more than 25%, not exactly 25%.
However, share ownership is not the only test.
Someone could still be considered to exercise control through other means, such as significant voting rights or the ability to appoint or remove a majority of the board.
A beneficial owner is essentially the person who ultimately owns or controls the company.
For a UK company, this can include an individual who:
These tests are broadly reflected in the UK's PSC framework as well.
This is usually a straightforward ownership structure.
For example:
Director/Shareholder → 100% → UK Limited Company
The provider will generally need to identify and verify that individual as the ultimate beneficial owner and may also verify them as the director or person acting for the company.
The same individual can therefore satisfy several roles in the KYC process.
Imagine a UK company has:
None automatically meets the more-than-25% shareholding test individually.
However, the provider still needs to understand the company's ownership and control structure and determine whether anyone exercises control through other means.
The provider may therefore request information about all shareholders even if none individually qualifies as a beneficial owner based purely on share ownership.
KYC can become more detailed when there are corporate shareholders.
For example:
Individual → Holding Company → UK Limited Company
The provider generally cannot stop simply at the holding company.
It must take reasonable measures to understand the ownership and control structure and identify the relevant ultimate beneficial owners.
This may require documents relating to:
Complex ownership structures can therefore take longer to verify.
Depending on the provider, an individual completing KYC may be asked for:
Identity verification may also be completed electronically.
A director or beneficial owner does not necessarily have to live in the UK to complete KYC for a UK company.
An overseas individual may be asked for:
The provider may also have its own country eligibility and risk requirements.
The concepts are closely related, but they arise under different legal frameworks and should not always be treated as completely interchangeable.
Companies House uses the Person with Significant Control (PSC) framework, while regulated financial providers apply beneficial-ownership requirements under AML legislation.
In many straightforward UK companies, however, the same individual will be both a PSC and a beneficial owner.
Yes.
The 25% threshold should not be interpreted as meaning a financial provider is prohibited from checking anyone below it.
Providers operate risk-based due diligence procedures and may require additional information or verification depending on:
KYC requirements can therefore differ between providers.
Yes.
Providers are required to conduct ongoing monitoring and keep customer information appropriately updated.
Further KYC may therefore be required if:
Keeping ownership and director information current can make these reviews easier.
Not necessarily in exactly the same way for every provider. Banks commonly collect information about directors, while relevant directors, beneficial owners and people acting on behalf of the company may need individual identity verification.
Not necessarily. Beneficial owners must be identified and appropriately verified, while providers may also request information about other shareholders depending on the company's structure and risk profile.
A 10% shareholder would not normally qualify as a beneficial owner solely because of that shareholding. However, the provider may still request information or verification depending on other control rights or its risk assessment.
Such a shareholder will generally fall within the beneficial-owner definition based on share ownership and therefore be subject to relevant customer due diligence measures.
The same individual can be verified as the director, beneficial owner and person authorised to operate the company's account.
Yes, potentially. They may be able to use overseas identification and proof of address, subject to the provider's eligibility and verification requirements.
No, not every director and shareholder of a UK limited company necessarily completes the same KYC process.
Financial providers generally need to understand the entire company structure, while particular attention is given to:
Beneficial owners → Controlling persons → Relevant directors → Authorised account users
Shareholders owning more than 25% are generally treated as beneficial owners based on share ownership, although individuals with smaller holdings can still require verification if they exercise significant control or the provider's risk assessment requires it.
For UK company owners, the safest approach is to have accurate identification, address and ownership information available for all directors and shareholders, even if the provider ultimately requires full individual verification from only some of them.
