New changes to the PSC requirements which affects UK companies and LLPs
Since 6 April 2016, UK companies and LLPs have been required to keep a PSC Register identifying those individuals or relevant legal entities which have significant influence or control over them. This information is then filed with Companies House once a year via a Confirmation Statement.
Why have PSC Register requirements changed?
The changes to PSC Register requirements have been introduced as a result of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“the Regulations”) which aim to help prevent money laundering and terrorist financing. The changes will increase the transparency of who owns and controls companies and LLPs in the UK.
What has changed with PSC Register requirements?
Under the previous regime updates to the Confirmation Statement were required annually unless a company or LLP has opted to keep its PSC Register on a central register. However, since 26 June 2017 companies and LLPs will need to inform Companies House whenever there is a change to their PSC Register. Companies and LLPs have 14 days to update their PSC Register and then another 14 days to send the information to Companies House using forms PSC01 and PSC09. Changes may arise as a result of any alterations to the share structure of a company e.g. following a share transfer, share buy back or company sale.
This new requirement to file information with Companies House throughout the year does add an extra administrative burden. However, as companies and LLPs need to keep an up to date PSC Register at the registered office address, hopefully this won’t cause too much extra work as companies and LLPs should be updating the information on their PSC Register when changes happen.
It is likely that additional legislation will be published shortly to ensure the UK’s compliance with the Regulations so please check our website for further details.
For more guidance on the PSC Register, please click here.