Important changes to PSC reporting

All companies and limited liability partnerships (LLPs) are required to identify and record the people with ‘significant control’ in a PSC register.

Previously, a company or LLP would make any changes to the PSC register as part of its annual confirmation statement submitted to Companies House. As of June 2017, all PSC changes must be directly reported to Companies House as and when they happen and not via the confirmation statement procedure.

Companies and LLPs must internally update their PSC register within 14 days and then within a further 14 days, report the changes to Companies House.

Changes that have been made and reported on the companies or LLP’s annual confirmation statement before 26 June 2017 will not have to be separately reported. However, those with outstanding updates to their PSC register following the filing of their annual confirmation statement on or after 26 June 2017, will need to follow the direct reporting process and adhere to the 14 day deadline.

Identifying people with significant control

Companies need to register an individual who meets one or more of the following conditions:

• directly or indirectly holds more than 25% of the company shares
• directly or indirectly holds more than 25% of the voting rights
• directly or indirectly holds the right to appoint or remove the majority of directors
• otherwise has the right to exercise, or actually exercise, significant influence or control or;
• has the right to exercise, or actually exercise, significant influence or control over the activities of a trust or firm which is not a legal entity, but would itself satisfy any of the first 4 conditions if it were an individual.

For further information on PSC Reporting, please contact Gary Brown on 023 8046 1239.