This article originally appeared in our September 11, 2025 edition of the Diligent Minute Newsletter. For more insights like these, delivered straight to your inbox, subscribe

Governance leaders feel more confident about AI these days, if the findings from our latest 

We asked GCs their key areas of risk right now, and only 8% mentioned technological disruption. This calm was a little surprising to me, given the current frenzy to integrate AI and see results as soon as possible.

AI risk perceptions among governance leaders

recent episode of the Corporate Director Podcast

 particularly timely. We talked to Beena Ammanath, Global Head of the Deloitte AI Institute and a faculty member for Diligent’s AI Ethics and Board Oversight Program. Ammanath’s literally written the book — 

 — on navigating tech disruption, and I always find her take on things very thoughtful, nuanced and reassuring, as you’ll see in these expert tips for AI strategy and adoption. 

Sticking with our GC theme, the paralegals who support them have typically followed an established career path. Early on, they spend a lot of time looking up statutes and contracts and reviewing documents. The information they learn along the way equips them for more senior roles.

But now AI has automated the whole process, transforming the team’s workload and profession’s overall pipeline and career trajectory. It leaves paralegals understandably worried — especially when they hear promises that AI will take away the boring parts of their work and make their jobs easier.

“Leaders have a responsibility to go beyond the clichés,” Ammanath said. “What happens to the workday when organizations make the job easier? If AI is going to create new jobs, what are those roles?”

“I think leaders have a huge responsibility to proactively think about that,” Ammanath said, citing the need to create organizational structures for new career paths and provide both targeted upskilling and general AI training to build fluency across the workforce.

Then there’s the matter of the human/machine relationship. “How can leaders thrive and succeed in this era of AI where humans and machines are working so closely together?” Ammanath asked. “To work in the best possible way, where can we get the maximum benefit with the minimum side effects?”

We’ve all seen cautionary tales about students outsourcing the entirety of their coursework to ChatGPT. This should go without saying but: Don’t do that in your organization.

In the podcast, my cohost Meghan Day and I talked about studies of what people’s brain waves look like when they use AI at different levels. The heaviest AI use showed the lowest brain function — almost like people were asleep. More optimal EKG activity happened when AI users started a task with their brains and then added ChatGPT.

“Personally, I’ve been most successful embracing AI in my job in areas where I already know what good looks like,” Day said. “And AI is able to speed my work along.”

AI also promises big potential for board members. You can train different agents to have different personalities and perspectives so they can frame problems in new ways for you, for example. But you’ll still need to oversee them and evaluate their output with your own human expertise to ensure accuracy and nuance.

3. Make continuous education — and hands-on use — a cultural norm

Navigating AI’s risks and rewards requires knowledge of AI itself.

This doesn’t mean dropping everything to become an AI expert (although those nine-figure job offers make it tempting). It means having a basic understanding of core AI principles, like machine learning, deep learning and computer vision — and what these principles look like in action.

“As corporate directors, it's important to focus the time and energy to not only learn about AI, but start using AI tools in your job,” Ammanath said.

AI is changing the way we work and the way we lead. For practical strategies and insights from Beena Ammanath,

listen to the full conversation on the Corporate Director Podcast: AI leadership strategies for a changing world.

Company Secretaries and General Counsels must soon guide their boards through a seismic change: Mandatory identity verification under the Economic Crime and Corporate Transparency Act (ECCTA). This new compliance requirement, beginning 18 November 2025, isn’t just a box-tick exercise — it demands board education, proactive engagement, strategic decisions about how and when verification is undertaken, and the best verification route for each U.K. entity.

This article breaks down the two official verification routes, explains who needs to act and when, and offers practical guidance to help Company Secretaries and General Counsel – particularly those based overseas - choose the best approach for their board.

Why boards must verify: Law and practical impacts

Under ECCTA, identity verification becomes mandatory for all company directors, Persons with Significant Control (PSCs) and LLP members. Directors must verify their identity and provide their IDV code in their company’s confirmation statement date, which will fall within a rolling period starting 18 November 2025 and ending in November 2026. PSCs must verify their identities within a defined period, depending on their specific circumstances.

If a director’s identity isn’t verified, the company won’t be able to file its confirmation statement with Companies House — leaving it non-compliant and potentially unable to operate. Failure to verify is also a criminal offence, punishable by fines and civil penalties issued by the Registrar of Companies. Where a PSC fails to verify their identity, they will be committing a criminal offence, but the company itself won’t be liable for sanctions.

From Spring/Summer 2026, secretarial and legal team members must also be verified to file documents. Without verification, they won’t be able to file with Companies House, putting group compliance at risk. Early action is advisable so teams can secure their personal codes and establish robust processes.

Government One Login vs. ACSP: Which route is best for your board?

There are two official routes to identity verification under ECCTA. Each option has its own strengths and limitations — and the right choice depends on your board’s composition, identity documentation and risk profile. Here’s how each route works — and what to consider:

1. GOV.UK One Login/Companies House Online

This route is designed for speed and simplicity. It’s ideal for UK-based individuals with biometric ID and complete the process online, allowing them to verify directly through GOV.UK and use their code across multiple roles and filings.

Ideal for UK nationals with biometric passports or UK driving licences

Individuals receive a reusable verification code for filings across all roles (director, PSC, or Companies House filer)

Requires acceptable documents (e.g. biometric UK passport or driving licence) and digital access

Requires ability to complete the process online via GOV.UK

Not suitable for overseas board members, politically exposed persons or those without biometric ID

2. Authorised Corporate Service Provider (ACSP)

ACSPs offer a more flexible, supported route — particularly useful for boards with overseas members, complex structures or individuals who don’t meet One Login criteria. These providers (e.g. accountants, law firms, formation agents) handle verification on your behalf, but charge a fee and apply their own risk assessments. 

 for a deeper dive into ACSPs and presenter ID requirements.

Suitable for boards with complex structures or higher compliance risk

Requires engagement with an external provider

ACSPs must meet strict standards and conduct their own risk assessments, which may require more documentation to be produced.

Mandatory identity verification starts 18 Nov. Learn how Diligent helps Company Secretaries and GCs simplify compliance and avoid last-minute filing risks.

Get ahead of ECCTA IDV

How to choose the right verification route

Choosing the right route isn’t just about eligibility — it's about understanding your board’s makeup, habits and preferences. A thoughtful approach will help governance teams avoid delays, reduce friction and build confidence in the process.

Here are 4 practical steps to help you choose the best route for your board:

 to identify directors and PSCs subject to the requirements. Survey them for eligibility (biometric passport/UK ID, digital access, residency). For most, One Login will be straightforward; for others, ACSP may be necessary.

Encourage the company secretarial team to test both routes early. Document each step and challenge and assess which option aligns best with board habits — including digital literacy, comfort with remote tasks, privacy concerns, personal logistics.

 Develop internal guidance based on team or board feedback. Include document requirements, costs, and help channels for future directors or company officers.

Tie verification into onboarding, offboarding, and annual board routines — especially succession planning. Ensure board members have their unique codes ready for upcoming confirmation statement filings.

The identity verification requirement comes into effect on 18 November 2025 — but the timeline for action depends on your company’s confirmation statement date and the roles involved. The mandatory period is triggered either by the company’s next confirmation statement or by the need to appoint a new director or PSC.

Planning ahead will help avoid last-minute issues and ensure a smooth transition.

Verification is required by the company’s next confirmation statement date, which will fall within a rolling period ending November 2026. New appointments must be verified before they can be registered.

 From spring/summer 2026, individuals must be verified to retain filing rights with Companies House. Early compliance ensures business continuity and gives teams valuable experience to support directors through the process.

Turning compliance into confidence: Embedding IDV into board routines

Identity verification isn’t just a one-off task — it’s something governance teams will need to manage continuously as directors join, leave or change roles. The most effective boards will treat IDV as part of their governance rhythm, embedding it into onboarding, offboarding and annual routines.

✅ Add IDV to your onboarding checklist for new directors and PSCs

✅ Include verification status in board succession planning

✅ Build internal guidance to support future filings and transitions

✅ Capture lessons from early pilots to improve future processes

By treating IDV as part of good governance — not just compliance — Company Secretaries and General Counsels can build confidence across the board and ensure long-term continuity.

Government One Login or ACSP? Making the right IDV choice for your board under ECCTA 

This article originally appeared in our August 28 edition of the Diligent Minute Newsletter. For more insights like these, delivered straight to your inbox, subscribe 

My colleague Josh Black, Vice President of Editorial at Diligent, doesn’t use words like “eventful” and “unconventional” lightly. So, when I saw them front and center in the editor’s forward of this year’s Proxy Season Review, which Diligent Market Intelligence prepares in association with Olshan Frome Wolosky and Campaign Management, I paid even more attention than usual.

“It is difficult to recall a more eventful or unconventional proxy season since the first year of the pandemic,” Black declared. 

Relentless market volatility is only part of it

. Activists have beena dopting new tactics and advancing stronger director candidates to achieve their desired objectives, especially in the U.S. “It feels very much like an inflection point,” Black added.

Proxy season 2025: Evolving shareholder engagement strategies

In this year’s review, his team examines this inflection point, connecting the dots between what we’ve seen in this year’s proxy season and what these trends mean for boards and advisors right now. Here are a few key takeaways, starting with shareholder engagement.

You’ve probably observed a noted decline in proactive communications by institutional investors lately. Regulatory developments, like revised guidance on Schedule 13D/G eligibility, are a big part of this.“ Norms have unmistakably evolved,” Campaign Management CEO and Founder Michael Fein pointed out in his analysis. “Institutional investors paused outreach, reassessed compliance exposure, and pulled back from dialogue just as several proxy campaigns were gathering momentum.”

Shareholders still care deeply about board structure, accountability, and transparency — critical contributors to strong corporate performance in uncertain times.

In the first half of the year, 33 governance-focused proposals passed with majority support. Board composition has been a common target, with director shuffles at Phillips 66 and Penn Entertainment far from isolated anomalies. We’ve also seen a significant increase in withhold campaigns for driving director changes and other demands.

2. Make real-time data and shareholder sentiment a board priority

Amid this perfect storm of new tactics, heightened scrutiny and radio silence from institutional investors, it’s harder than ever to anticipate vote dynamics and activist positioning.

Is a withhold campaign targeted pressure for governance enhancements, or a prelude to a full-blown proxy fight? Your company’s future depends on answering questions like these quickly and well. And this means moving beyond historical data, guesswork and ad hoc interpretation to real-time intelligence.

Now is the time to invest in systems and processes that deliver accurate, actionable data on investor sentiment, proxy trends, and governance benchmarks.

It’s time to look beyond business as usual for shareholder engagement as well. This means rethinking how your organization interacts with institutional investors. What new touchpoints can you leverage to fill in communication gaps? How can you proactively share your governance story — especially future-focused strategies and positive milestones — in a way that responds to current trends and sentiment?

Think about harnessing all of the data collected in the steps above, like 

 and proposal outcomes, to shape your narrative. “The 2025 proxy season made clear that activists will not sit on the sidelines waiting for more ideal economic conditions,” Andrew Freedman, Chair of Olshan Frome Wolosky’s Shareholder Activism Practice Group, warned in this year’s review. And here’s what he recommends: “Stay prepared to respond to well-crafted demands and sharp strategies, underscored by an unwavering focus on performance and accountability.”

Keep reading for more on the 2025 proxy season

Dive into our full analysis — AI, ESG, 2025’s wildest campaigns and much more — in the full report: The Proxy Season Review 2025.

Want regular access to original research in the field of GRC? Bookmark our 

 for the latest surveys, podcasts and reports.

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AI risk perceptions among governance leaders

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