June 12th, 2017

PSC Register Changes

The PSC (Persons with Significant Control) regime is due to change on 26 June 2017 when the provisions of the EU’s Fourth Money Laundering Directive are implemented into UK law.

At present, all companies are required to ‘check and confirm’ PSC information, via their annual confirmation statement (CS01). From 26th June the filing of PSC will become event driven. Companies that have changes in PSC information will have 14 days to update their register from the date when the information is confirmed and a further 14 days to send the information to Companies House using the new PSC01 to PSC09 forms.

The annual confirmation statement will continue to include PSC information and companies will have to confirm in that statement that the PSC information is correct but it will no longer be possible to update PSC data on the CS01.

This change will be implemented on 26th June 2017 and as such will create a ‘gap’ between this date and the 29th June 2017 for some companies who have not filed a CS01. Companies whose CS01 is due to be filed between these dates will need to notify their PSC details on the relevant form.

Companies who have had changes in PSC since their last annual filing will also be required to notify Companies House of these changes with one of the new forms.

We are informed by Companies House that over the last year they have been taking a ‘light touch’ approach to PSC compliance but with the new regulations they will be taking a more proactive stance. If a company for example makes a statement that they are still investigating their PSCs, they will chase that company when the statement is over 8 weeks old as they would expect the company to have either found their PSC or issued notices.

The new rules impose a considerable extra burden on company administrators. When dealing with a share transfer, you will need to consider the implications for PSCs and take action accordingly.

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Contacts

Jon Round

Managing Director

0113 224 5488

jon.round@yorkplace.com


Nicola Cowburn

Formations Manager

0113 224 5456

nicola.cowburn@yorkplace.com

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