The People with Significant Control (PSC) register, which records individuals or entities with significant influence or control over your company or partnership, has changed recently.
The PSC register was originally introduced through the Companies Act in 2006 and reinforced by the Small Business, Enterprise and Employment Act again in 2015, with the goal of increased transparency in business ownership and control, combatting money laundering, and fostering greater trust in UK businesses.
However, it comes with a few complications and responsibilities on your part that, if not adhered to, could cause you some problems.
Recently, the Economic Crime and Corporate Transparency Act 2023 (ECCTA) has brought some further changes to the PSC regime, which became effective in February 2024.
These were designed to streamline the process of maintaining your PSC information and enhance the reliability of the data held by Companies House.
We think one of the most notable changes was the centralisation of PSC information at Companies House.
You are now required to upload your PSC details directly to Companies House, eliminating the need to maintain separate PSC registers.
The other change we think you should be aware of, introduced by the ECCTA, is the requirement for ID verification for PSCs and nominated managing officers.
This step ensures the accuracy and integrity of the information provided, further strengthening the regime against misuse and fraud.
Both of these changes, however, mean you’ll need to adapt your internal processes to comply with the new regulations, ensuring that all relevant PSC information is accurately recorded and regularly updated.
Here’s how we’re advising our clients to manage their compliance requirements.
Our advice for maintaining compliance with the new regulations
The first step is ensuring your PSC register is up to date with all relevant information, including any changes in PSCs.
This will involve identifying individuals or entities with significant control over your business and understanding the complexities of the control structures within your organisation.
You’ll need to perform regular reviews and update any relevant information to keep your records accurate.
Submitting information to Companies House is, of course, a mandatory step in the process.
You’ll also need to implement procedures for ID verification for PSCs and nominated managing officers.
You may need to establish new protocols within your company to verify identities and ensure that all information submitted is accurate and trustworthy.
We’ve noticed that challenges in maintaining compliance often arise from identifying indirect PSCs and understanding joint arrangements that might confer control.
In these cases, we highly recommend seeking professional advice from your accountant and conducting thorough analyses of your corporate structure and governance arrangements which can help you accurately identify all PSCs.
Accurate and up-to-date records are not just a regulatory requirement but also a good business practice.
They can help you avoid potential penalties and ensure smooth business operations.
As your accountant, we can help you navigate these changes and keep you informed about the latest regulatory updates, help you maintain accurate PSC registers, and assist with submissions to Companies House.
We’ll help ensure that your company remains compliant with the new regulations and avoids any potential pitfalls.
