Important new changes to the People with Significant Control (PSC) regime came into effect on 26th June 2017 affecting all UK privately owned companies/subsidiaries and LLPs. Unregistered companies and companies with shares admitted to AIM and the Nex Exchange are now also subject to the regime for registering PSCs and eligible Scottish partnerships are required to file information on their PSCs with Companies House.
New 14-day longstop period for updating PSC register and using investigatory notices:
When there is a change to the information in a company’s PSC register, it will now have 14 days to update it. The 14-day clock starts to run when the company holds all the information that it needs to update the register.
A new 14-day longstop period also applies to the issue of investigatory notices when a company knows or suspects that there has been a change to its PSC information.
New event driven PSC filing requirements:
The Fourth Money Laundering Directive requires information on the central register to be current and companies will now have a 14-day period which starts to run the day after it has updated its own PSC register to notify Companies House of the changes.
Companies no longer need to deliver their PSC register information to Companies House at the same time as their annual confirmation statement, but they do need to confirm (in their confirmation statement) that they have complied with the new PSC regime requirements.
If you have previously filed a confirmation statement, file at Companies House all changes made to your PSC register between your last confirmation statement date and 26 June 2017 using forms PSC01 to PSC09 as soon as possible.
Failure to provide the necessary information within the new prescribed timescale may result in a fine or a prison sentence of up to two years
Further Information and Legal Support
In the meantime, if you need any further information or would like help carrying out your PSC register analysis, please contact a member of our Corporate Team.
LEGAL VIEW CORPORATE TEAM