BFI Introduces Mandatory ID Verification for AVEC Cultural Test Applications

From June 1, 2026 the British Film Institute (BFI) is introducing mandatory ID verification for the directors of production companies submitting interim and final Cultural Test applications under the UK’s Audio-Visual Expenditure Credit (AVEC).

The Cultural Test is a requirement for all film and high-end television productions seeking to qualify for the AVEC – the UK's primary production incentive, which offers a 25.5% payable credit on qualifying UK expenditure and an up to 39.75% rate for certain productions. Productions must obtain BFI certification at both interim and final stages to access the credit, making the Cultural Test a critical step in the incentive claims process.

The new ID verification requirement applies to all directors of the UK production company, including where US producers are structuring projects through a UK entity to access the AVEC. It will only impact directors of the production company submitting the application – not cast, crew or creative talent – and applies to all new interim and final Cultural Test applications submitted on or after June 1, 2026.

This guide covers everything productions need to know about the change: what documents are required, how the process works for non-UK resident directors, how long verifications remain valid, and whether the new requirement is likely to affect application turnaround times or a production's ability to qualify for the Cultural Test.

For a comprehensive overview of how the UK Cultural Test works and the points available under each section, see our complete guide for producers.

What is required to complete ID verification for Cultural Test applications?

The ID verification process is relatively straightforward and not overly onerous.

For each director of the production company applying for a Cultural Test certificate, the BFI will require their:

• Full legal name;
• Date of birth;
• Contact email address;
• Current residential address; and
• Previous residential address (if moved within the past three months)

The verification form can be submitted alongside the Cultural Test so if Entertainment Partners is supporting you with your Cultural Test application, our team can also assist with the submission of the required information.

If I am not a UK resident will that impact the ID verification check?

For UK residents, the information listed above will likely be sufficient for the BFI to be able to confirm identity.

For non-UK residents, additional information may be required to allow the BFI to confirm identity, although the extent of this remains to be seen. That said, the BFI will be aware that many applicant companies will have non-UK directors and will have considered this as part of their process design.

How long will ID checks be valid for?

One ID check covers all companies where the individual is a director and remains valid for six months, so directors should need to verify their identity no more than twice a year. 

How long will the BFI store my data for?

The BFI’s guidance states the following about the use and storage of director data:

By submitting this form, you are providing your informed consent (and permission) for the BFI to run an identity check on you, including its access, use and storage. The information you give us will be held on an internal management system for the administration of applications and will be deleted 6 months after verification.

We may use a credit reference agency to validate information you have provided in your application. This is not a credit check and will not affect your ability to receive credit from other organisations. The credit reference agency we use may keep a record of the information and may disclose the fact that a search of its records was made to its other clients, in order to prevent fraud.

Why is the BFI introducing ID verification for Cultural Test applications?

These checks are part of continuous enhancements made by the BFI and HMRC to improve their counter-fraud measures to safeguard the integrity of the UK incentive regime and ensure that it is being appropriately used.

ID verification of the directors of applicant companies also allows the BFI to readily check if key individuals associated with the organisation raise any immediate or obvious economic crime concerns.

Will the ID verification requirement impact turnaround times for Cultural Test certificates?

The BFI has stated that it will be unable to issue certificates if it has not completed ID checks on the company directors; therefore, this change could slow down turnaround times.

However, if the information is provided alongside the application, the additional burden of ID verification for a few company directors should not materially increase the time that it takes the BFI to review the application. We therefore do not anticipate a material increase in the current six-to-eight week turnaround time from the BFI.

Will this impact qualification for the Cultural Test?

No – this does not impact the underlying qualification and requirements for passing the Cultural Test. The nationality or residency of company directors does not impact the Cultural Test and there is no intent for this requirement to impact the Cultural Test. This change is simply part of enhanced anti-fraud measures being introduced to safeguard the UK incentives regime.

However, if you fail to submit the ID verification form for your company directors, the BFI will not issue your Cultural Test certificate.

Get expert support accessing the UK AVEC with Entertainment Partners

If you’d like to know more about how to access the UK AVEC on your production, contact Entertainment Partners today!

With vast experience in global and domestic tax incentives, our expert UK team can help you to maximise your budget and can assist with structuring advice, Cultural Test applications and associated reports, film and TV incentives estimates, formal opinions to lenders, incentive claim submissions and deal close support.

This article contains general information we are providing on a subject that may be of interest to you. Nothing in this article should be considered tax, accounting, or legal advice. You should consult with your own advisors regarding the applicability of this information to your specific circumstances.