UK: Business Bites: PSC Register Update

The requirement for companies and LLPs to maintain a Register of People with Significant Control (PSC Register) came into force in April 2016, with the PSC Register being filed with Companies House as part of a company's Confirmation Statement from July that year. However, the way in which a company's PSC Register will be reported to Companies House will shortly be changing.

From 26 June 2017, any change to a company's PSC Register will require to be notified by way of a separate Companies House PSC form as and when the changes occur, as opposed to being reported annually via the Confirmation Statement.

The implication of this is that if a company or LLP has made any changes to its PSC Register since its last Confirmation Statement was filed, the appropriate PSC form will require to be filed with Companies House – and the window for making this filing, to comply with the regulations, is 26 June to 9 July 2017. Alternatively, in order to eliminate the need for a PSC form to be filed during this time, an additional/interim Confirmation Statement can be filed prior to 26 June 2017.

From 26 June 2017, it is therefore important to remember that any changes to a company's or LLP's PSC Register will require to be updated in the statutory registers within 14 days and notified to Companies House within a further 14 days of the change*, via the appropriate prescribed PSC form. Any Confirmation Statements filed with Companies House on or after 26 June 2017 in the current format will be rejected, even if the Confirmation Statement date is prior to 26 June.

*UPDATE ADDED 30 JUNE 2017: Good news! We originally stated that changes to a company's or LLP's PSC Register required to be filed with Companies House within 15 days of the change. However, official guidance has now been published by Companies House confirming that the deadline is in fact 28 days from the date of the change.

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