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Additional requirements for PSCs



New rules introduced in 2016 imposed a series of new obligations on UK companies and limited liability partnerships (LLPs), as well as those holding interests in UK companies.

Since April 2016, most companies have been required to produce and maintain a register of Persons with Significant Control, or PSC register, which provides details of those who ultimately control or exercise significant control over the company. From 30 June 2016, companies were required to submit their PSC information to Companies House via their confirmation statement (which replaced the previous annual return).

However, as part of the implementation of the Fourth Money Laundering Directive (4MLD), additional rules have now been introduced, meaning that PSCs are no longer updated annually via the confirmation statement, but instead must be maintained in real time.

Under the new rules, if a company has reason to believe that details relating to a PSC have changed, it will need to act swiftly to determine the change.

Where a relevant change occurs, the PSC register must be updated within 14 days of the company becoming aware of the amendment, and the changes must be submitted to Companies House within a further 14 days.

The confirmation statement still needs to be filed each year, including to record where a company is exempt from the need to supply information on PSCs.

The PSC regime has also now been extended to apply to Scottish limited partnerships (SLPs) and Scottish qualified partnerships.