PSC Guidance and templates updated following changes to PSC Regime
The purpose of the people with significant control (PSC) regime is to provide greater transparency of corporate ownership and control of UK incorporated companies and other entities such as LLPs. The regime requires in-scope entities to identify individuals that ultimately own and control them, and then to notify them to Companies House for inclusion on the public register.
The regime has most recently been updated as of 18th November 2025 by the Economic Crime and Corporate Transparency Act 2023. From 18th November 2025, the requirement for companies to keep their own PSC register has been abolished and the PSC notification regime amended. The updated regime is both more complex and more prescriptive. All information must now be notified directly to Companies House (using Companies House forms PSC01 to PSC09). This includes the identity of each of their PSCs and of any subsequent change to PSC information. The notification needs to include certain information about the PSC known as "required particulars". If a company is missing any of the required particulars, it cannot notify Companies House in relation to the identity of the PSC until all the particulars are confirmed and instead should serve a notice on the PSC or RLE to obtain the necessary information.
In addition, on 4 March 2026, the government has published updated statutory guidance for companies and LLPs on the meaning of ”significant influence or control” in the context of the register of PSCs.
All in scope entities are required to take reasonable steps to to find out if anyone is a PSC in relation to the entity, to identify them and notify this information, and changes to it, to Companies House. If they do not have a PSC, they must still notify this information to Companies House. Notifications must be sent to Companies House within 14 days of a company having confirmation of the PSC information. The PSC register cannot be left blank. If a company has taken all reasonable steps to ascertain whether it has any registrable PSCs or RLEs and has concluded there are none, it must use form PSC08 to notify Companies House that the company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company.
Failure to comply with the regime and provide accurate and timely information to Companies House without a reasonable excuse, is a criminal offence by companies, their officers and those required to provide the relevant information.
In addition, mandatory identity verification has been introduced for individual PSCs.
Considering the changes made to the PSC regime, we have updated our suite of PSC templates. This includes:
- our guidance note and checklist;
- statutory notices;
- letters and pro-forma replies from PSCs;
- PSC and RLE registers; and
- Companies House forms PSC01 to PSC09.
The contents of this Newsletter are for reference purposes only and do not constitute legal advice. Independent legal advice should be sought in relation to any specific legal matter.