Most compliance failures in international groups are not caused by ignorance of the rules. They are caused by nobody owning the calendar.
The final quarter of 2026 is unusually crowded. The UK's director identity verification regime ends its transition year, e-invoicing mandates are live or landing across a string of EU markets, and 2027 deadlines are close enough that systems work has to start now. For a group with entities in four or five countries, each obligation is manageable. Together, without a single owner, they are how penalties, blocked filings and frozen payments happen.
Companies House identity verification became a legal requirement on 18 November 2025 under the Economic Crime and Corporate Transparency Act. That date opened a twelve month transition for existing directors and people with significant control, which closes in mid-November 2026. Companies House estimated that 6 to 7 million individuals would need to verify.
The point most groups miss is that 18 November is a backstop, not the deadline. During the transition, existing directors supply their personal code with the company's next confirmation statement. If that statement falls due in October, October is the deadline. A director who sits on several UK boards is bound by the earliest date across all of them.
Overseas directors are the usual weak spot. Foreign passports, name transliterations and mismatched dates of birth on older records can turn a three minute online check into a weeks long exercise through an authorised agent. Companies House has said it will take proportionate action against those who fail to verify once the transition ends, and it will be an offence to act as a director without being verified.
There is no single EU e-invoicing date. Each member state is moving on its own timetable and, in several cases, its own technical model.
Behind all of this sits the EU's VAT in the Digital Age package, which sets 1 July 2030 for digital reporting on cross-border transactions. The direction is settled. Only the pace varies.
For a group, the practical problem is that Poland uses a government clearance model, Belgium uses Peppol, France uses accredited platforms and Germany prescribes the data standard rather than the route. A finance function still running on PDFs and email cannot receive a valid invoice from a Polish or Belgian supplier, let alone issue one.
We see the same three patterns repeatedly. First, obligations are owned locally by whoever happens to administer each entity, so nobody sees the whole picture. Second, deadlines live in people's heads or in an adviser's inbox rather than in a shared calendar with named owners. Third, the finance system is treated as a local purchase, so every new mandate becomes a separate integration project.
None of this is a legal problem. It is an operating model problem. Groups that handle it well put one executive in charge of the entity estate, keep a live register of every obligation with its owner and due date, and choose invoicing infrastructure once, at group level, rather than country by country.
The transition period for existing directors and people with significant control ends in mid-November 2026. In practice, most existing directors must verify by their company's next confirmation statement date, which may fall earlier.
Yes. Every director and person with significant control must verify, wherever they live. Those without UK documents can verify through GOV.UK One Login with accepted foreign documents or through an Authorised Corporate Service Provider.
Belgium, Poland, France and Greece all brought in or extended B2B mandates during 2026, alongside Italy and Romania, which already had them. Germany requires businesses to receive e-invoices and phases in issuing obligations from 2027.
For businesses within the mandate, an invoice issued outside KSeF is not a valid invoice under Polish VAT law. Offline mode exists for outages, but the invoice must still be submitted to KSeF shortly afterwards.
One named executive, usually the CFO or a group company secretary, should own a single register of every entity obligation, with local owners accountable for delivery against it.
Grant & Graham sets up and runs company structures in more than 100 jurisdictions and places senior finance and operations leaders when a group's compliance model needs rebuilding. Explore our company formation and ongoing compliance service, our interim management practice, or book a call with Andrew Collins.
This article is general information, not legal or tax advice. Dates reflect published guidance as of September 2026 and should be confirmed with local advisers.