As part of the new bill, companies will be required from April 2016 to keep a register of People with significant control over that company. From June 2016 this information must be provided to Companies House (CH). The company must keep its PSC register publicly accessible, which can be at the companies registered office, Companies House or another location provided you have notified CH.
By choosing to elect to keep the PSC register at CH the full date of birth of all PSCs will be made public and all PSC information must be kept up to date by filing the information to CH.
Would it be possible to see a sample register of what Companies House expects the register to look like? It would be helpful to understand, how the register is expected to be laid out. If for example a PSC is identified but the details not confirmed, but then the PSC confirms details how do CH expect that to be presented? Would the initial status that PSC has been identified and not confirmed remain with a date that it ceased to be true, followed by and entry with the confirmed PSC details?
HI
You will be expected to either file a notification form PSC01,2,3 to notify us of a PSC or if you don’t have the details for your PSC then a PSC08, which is a statement/reason why you are unable to provide details. Further details on statements can be found here: http://xmlforum.aws.chdev.org/t/persons-with-significant-control-psc-statements/29/2
Once these no longer apply you would need to submit a PSC09 to indicate that statement no longer applies and follow that up with a notification form to confirm their details.
Not sure if you have already seen this guidance published to see if this clarifies the complexities of PSCs.
https://www.icsa.org.uk/assets/files/pdfs/Policy/PSC-Draft-Guidance-for-companies-17-December-2015.pdf
Hope that helps
Charlotte
Hi Charlotte,
I’m trying to nail down why you would hold the register at your registered office, rather than at Companies House.
From what I can see:
- Day of birth is hidden at CH (but from what I understand you would still need to have day of birth available for inspection at your registered office anyway?)
- PSC info only needs to be updated at CH once a year in the confirmation statement (but must still be up to date at the registered office at all times)
Is there anything else?
If you choose to hold the register at Companies House will it provide the full historical info of previous PSCs etc.?
From what I’ve documented above, I don’t see a benefit to holding it at the registered office. I guess I’m wondering why holding it at the registered office is even an option? Do you know the thinking behind it?
HI.
There are a few differences between holding at RO than at CH:
Electing to hold at CH means:
-
The full DOB will be shown on our services (you are correct you would need to show if someone wants to inspect register at RO), if you unelect to hold your register at CH, then the full DOB is always shown on the historical view of the register.
-
You are unable to file PSC information via a confirmation statement, you will need to file the individual forms when the event occurs - same as officer forms.
-
When you unelect to hold a company register at CH, we will show a snapshot (historical view) of what the data looked like at the point in time you withdrew.
Why hold at RO?
It depends on the company and the people involved, some people wouldn’t want their full DOB show on our services and only want to file via a confirmation statement. We cant recommend either option its up to you to look at the options and decide whats best. I hope that helps make it clearer.
Thanks for the in depth response Charlotte. Appreciated.