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Persons of Significant Control (PSC) register: the next instalment

17 July 2017

 

By now, you’ll be aware of the requirement to file information about individuals deemed to have ‘significant control’ over any companies or limited liability partnerships (LLPs) that you are involved with. Our previous briefing on the PSC register is available here.

After a year in force, the regulations have been updated to amend and clarify the rules affecting PSC registers.

Among the changes, the format and timing of reporting PSCs to Companies House have changed significantly. Here are the key points.

  • The annual confirmation statement (previously known as the annual return) will no longer include any information on PSCs.  Instead, any changes in the details of a PSC will follow a similar route to that currently used for changes in directors’ details: a specific form filed at Companies House.
  • Timing of filing. Any change to a PSC must now be updated on your company or LLP’s internal PSC register within 14 days. This information must then be filed at Companies House within a further 14 days.  This changes what was previously an annual filing position to a real-time notification to Companies House within 28 days of the change.
  • If there are no changes to your company or LLP’s registers in a 12 month period, your company or LLP is just required to confirm this to Companies House annually.

These are seemingly innocuous changes. But they create a need for your company or LLP to think more actively about its PSCs and keep its filings up to date.

The PSC register remains a matter of law. It is a criminal offence for a company or LLP to fail to take reasonable steps to comply with the legislation, or for a PSC to refuse to provide information to the company or LLP.

If you aren’t sure whether a change in your organisation constitutes a change for your PSC register, or if you would like assistance in keeping your PSC register up to date to meet your legal obligations, please get in touch with your usual BKL contact or by using our enquiry form.