On Monday 26 June the Information about People with Significant Control (Amendment) Regulations 2017 (“Regulations”) came into force. The Regulations modify and extend the existing national PSC register measures in order to complete the UK’s transposition of the transparency requirements relating to the beneficial ownership of companies and LLPs which were contained in the 2015 European Directive on the prevention of money laundering and terrorist financing.
1. Widen the scope of companies falling within the PSC regime
- Companies listed on UK secondary markets such as the Alternative Investment Market (“AIM”) or the NEX Exchange are no longer exempt from the PSC regime. These companies must now prepare and maintain PSC registers and comply with all relevant filing requirements in relation to PSC information in the same way that UK private companies do.
- The existing PSC measures (as amended by the Regulations) also now apply to unregistered companies.
Any companies which are newly subject to the PSC rules have until 24 July 2017 to comply.
2. Change to the companies house filing requirement
- PSC register filings are now event driven.
- 14 day time limits have been introduced for companies and LLPs to comply with their duty to:
- serve notices requesting information,
- enter information on their PSC registers, and
- give notice to Companies House of any changes to their PSC registers.
Companies House Forms PSC01 – PSC09 should be used to notify Companies House of any changes.
- Any company or LLP which has updated its internal PSC register since its last confirmation statement date has until 10 July 2017 to file the necessary forms with Companies House to bring the public register into line with the internal register.
This is a big change from the previous rules which only required a company or LLP to update its PSC information on the public register annually, as part of its confirmation statement.
For further information about the PSC regime, and how it applies to your company, LLP or Scottish Limited Partnership please see our briefing note - The UK PSC Register Requirements: A Practical Guide, or contact James Waddell, head of corporate (James.Waddell@stevens-bolton.com), or your usual S&B contact.