As of April 2016, most UK limited companies and limited liability partnerships (LLPs) have been required to hold and maintain a register of people with significant control. The PSC Register as it is known must be filed with Companies House on incorporation and as part of a company’s annual confirmation statement as of June 2016.
With the regime only still fairly new, it has come as something of a surprise to the business world that changes have already been introduced as of 26th June 2017.
EU Fourth Money Laundering Directive
These changes have come about as part of the EU Fourth Money Laundering Directive (MLD4) covering anti-money laundering and anti-terrorist financing measures. Whilst the UK is still part of the UK, the laws will apply.
Companies House has decided that the accuracy and completeness of current PSC data needs to be improved. Companies will therefore now be required to report any changes to their PSC information in real time as they happen, rather than wait until the annual confirmation statement is submitted.
The changes dictate that where there is a change to the information, companies will now have a 14-day timescale during which they must update their PSC register, plus a further 14 days in which to notify Companies House. The forms to be used are PSC01 (give notice of individual person with significant control) and PSC09 (give notice of update to PSC statements.
Support Available from Companies House
Companies House has issued a statement saying that for those companies requiring additional support in understanding the PSC regime, there will be individual assistance, particularly for those known to have submitted incorrect PSC information. Further guidance will be issued by Companies House, as well as a ‘report it now’ link being added to its website.
The Regulations governing these changes are yet to be released, but are expected very soon. Guidance notes are also awaited and we will share these as soon as they emerge. Be sure to follow us on Twitter and regularly check back to our news feed to keep up to date.