PSC Register Changes
Prior to 26th June, every company was required to ‘check and confirm’ their PSC information on their annual confirmation statement (CS01). The filing of PSC changes has now become become event driven. Every time a company’s PSCs change, or the details of an existing PSC change, the company will 14 have days to update their register from the date when the information is confirmed and a further 14 days to submit the information to Companies House on the new forms (PSC01, PSC02, PSC03, PSC04, PSC05, PSC06, PSC07, PSC08 & PSC09).
The CS01 continues to contain PSC information and companies will have to confirm in that statement that their PSC information is correct, but it will no longer be possible to update the information in the form.
The change was implemented on 26th June 2017, having been laid before parliament on the 22nd of June, and has created a ‘gap’ between 26th June and 29th June 2017 for some companies who have not yet been required to file a CS01.
Companies whose CS01 is due to be filed between these dates will need to notify their PSC details on the relevant form.
Companies who have had changes to their PSCs since their last annual filing will also be required to notify the Registrar of Companies of these changes.
We have been informed by Companies House that since the implementation of the original PSC legislation they have been taking a ‘light touch’ approach to compliance. However, with the new regulations they will be taking a more proactive stance and if a company, for example, makes a statement that they are still investigating their PSCs, then they will chase that company when the statement is over 8 weeks old, expecting it to have been resolved.
These new PSC rules create a considerable extra burden on company administrators. When dealing with a share transfer, for example, the implications from a PSC standpoint will need to be considered and appropriate action taken.
Scottish Limited Partnerships (SLP)
SLPs have previously been exempt from the register. From 24th July, active SLPs must register PSC information. This information must also be provided within 14 days. From 24th July, there will be a need to give PSC information when registering a new SLP.
General Scottish Partnerships (SP)
From 24th July, any SPs where all the partners are corporate bodies, need to register PSC information and confirm it once a year on a confirmation statement.
If you require advice or assistance with PSC filing please contact our company secretarial department.
