Company PSC Regime – Are you keeping up to date?

The advent of the PSC Regime on 6 April 2016 meant that the vast majority of UK companies and UK limited liability partnerships became required to maintain a register of "persons who have significant control" over such company or LLP. Just as companies have become used to the requirements of the PSC Regime further changes recently came into force which mean that the requirements have been changed as follows:

• AIM companies are now subject to the PSC Regime;
• the PSC Regime has been extended to include Scottish limited partnerships;
• new 14 day time limits apply in relation to updating an entity's PSC Register and updating the PSC Register at Companies House; and
• no longer can the Confirmation Statement be relied upon as being the main way for updating a PSC Register. Relying on this will no doubt mean that entities are out of date and out of time updating their Register with any changes.

Companies should be aware that the above changes came into force from 26 June 2017. The reason for the changes is the implementation of new Money Laundering Regulations which also came into force at that time. As a result all entities who are required to keep a PSC Register must:

1. Update their register within 14 days of any changes to the persons who exert or have significant control over their entity; and
2. Such changes must also be notified to Companies House within 14 days of any changes. Any entities who previously relied on the annual Confirmation Statement as being the vehicle under which they updated their PSC Register can no longer do so.

Updating Companies House

All notifications to Companies House regarding any the PSC Register must now be submitted on Forms PSC01 to PSC09.

Please do not hesitate to contact John Flanagan on 01482 337308 if you have any further queries in relation to your obligations and requirements under the PSC Regime.

This article is for general guidance only. It provides useful information in a concise form. Action should not be taken without obtaining specific legal advice.