Important Changes to the PSC Regime as of 26th June 2017

As reported in our June newsletter, changes have been made to the People with Significant Control (PSC) regime as of 26th June 2017. These changes, most particularly the change to filing deadlines, will affect all entities that are within scope of the regime. This means almost all UK companies and all UK LLPs need to consider and update the way they make changes to their PSC register and notify Companies House of these changes.

What has changed?

The most significant change for our customers is the new filing deadlines. Companies and LLPs must:

• record changes on their own PSC register within 14 days of obtaining the relevant information in relation to any change; and
• notify Companies House of the change within a further 14 days on forms PSC 01 – PSC 09 (or the LLP equivalent, forms LL PSC01 – LL PSC09). This is a significant change from the previous practice of providing PSC disclosures to Companies House once a year as part of the annual confirmation statement.

The PSC regime has also been extended to bring new entities such as AIM companies and certain Scottish partnerships within scope.

Companies (and LLPs) must be alert to the new 14 day longstop periods for updating and filing PSC information. They must also issue investigatory notices and put in place appropriate internal processes to ensure these requirements are met. Remember it is a criminal offence not to comply with the PSC regime!

In order to assist you in doing this, we have reviewed our PSC templates and updated our relevant guidance notes, PSC templates and Companies House forms to reflect these recent changes.

This will be of interest to all those involved in the management and administration of companies and LLPs.

More information is available for free on Companies House website.