Expected information to be submitted for Confirmation Statement PSC sections

Number 2 & 3 you are spot on. The first one however yes technically we wouldnt stop you filing that combination, because the statements are not linked to PSCs we dont know whether you are filing those 3 statements for 1 PSC or 3 different PSCs. We would advise you to send them in separately, so as soon as one doesnt apply you withdraw it and submit the next statement which applies. This will make it clearer for customers to follow through each PSC what has happened, by looking at the dates on each statement, unfortunately as they are not linked thats the only way to work it out.
Hope that answers your queries - its very complicated

Thank you for the reply

Having discussed this with my colleagues we are surprised that where there have been a number of changes in relation to PSCs that this means that a number of confirmation statements need to be submitted covering that confirmation statement period.

Surely all the PSC changes should be included in one confirmation statement as this will give the full history to Companies House as required?

By forcing companies to submit several statements with the different PSC changes included this is adding to the administrative burden of companies rather than removing or keeping such a burden to a minimum, which was part of the purpose of the move to the confirmation statement required by the SBEE?

In addition requiring multiple confirmation statements to be submitted for the year in question will mean that the earlier confirmation statements will not be correct at the confirmation statement date, as they will only have the earliest PSC details included. It will only be the last confirmation statement at the confirmation date that has the correct end PSC position.

Can you please confirm that it is true that Companies House will be requiring multiple confirmation statements with the same confirmation date to be submitted where certain PSC changes have taken place in the confirmation year covered by the confirmation statement rather than just one confirmation statement?

Given that, we understand that it is the case that separate confirmation statements will be needed for electronic submissions where certain PSC changes have been made, can you please confirm the situations where a PSC change in a confirmation statement period means that a separate confirmation statement is required given your earlier comment that in one scenario I provided that these could be submitted on one confirmation statement.

@cchrist n relation to the above, based on my interpretation of the topic content to help in your response, and associated matters can you please confirm or otherwise the following:

  1. the below is a correct summary of when Companies House requires a separate confirmation statement to be submitted in relation to PSCs:
    i. a companywide statement and one or more PSC statement or PSC notification applied in the same confirmation period;
    ii. a PSC notification and a confirmed change notification to that PSC applied in the same confirmation period;
    iii. a PSC notification and an unconfirmed change notification to that PSC applied in the same confirmation period;
    iv. an unconfirmed change notification to a PSC, which was subsequently confirmed applied in the same confirmation period;
    v. more than one change applied to a PSC in the same confirmation period
    vi a PSC notification and a PSC withdrawal for that PSC applied in the same confirmation period
    vii a PSC confirmed change notification and a PSC withdrawal for that same PSC applied in the same confirmation period
    viii a PSC unconfirmed change notification and a PSC withdrawal for the same PSC applied in the same confirmation period
  2. the ‘ReviewDate’ for each submission that needs to be submitted can be the same date so that the subsequent submissions are not rejected as duplicate submissions.
  3. any combination of PSC Statement Notifications, PSC Statement Withdrawals and PSC Notifications can be submitted on one confirmation statement.
  4. any combination of PSC Statement Notifications, PSC Statement Withdrawals and PSC Withdrawals can be submitted on one confirmation statement.
  5. any combination of PSC Statement Notifications, PSC Statement Withdrawals and PSC Changes, where none of the PSC Changes relate to the same PSC can be submitted on one confirmation statement.
  6. any combination of PSC Statement Notifications, PSC Statement Withdrawals, PSC Notifications and PSC Withdrawals, PSC changes where none of the PSC notifications, withdrawals and changes relate to the same person can be submitted on one confirmation statement.
  7. one Company statement withdrawal and any of 3, 4, 5 or 6 above.

Thanks

Philip

ps having just had a look at the business rules for the confirmation statement and the combination of PSC data given the above and earlier responses do not agree as the business rules imply that it is only PSC Statement notification with company statement that cannot be included in the same confirmation statement as a PSC statement notification with PSC notification, a PSC statement notification with PSC linked notification or a PSC notification, or multiple PSC statement notifications each with company statement.

hi. I am sorry you have had to wait so long I am continuing to chase our policy department to get your questions answered as we have had similar questions from other developers. Hopefully get an answer for you tomorrow - apologies again

@chirst sorry to chase but as our developers are keen to understand Companies House’s requirements for this do you have a response yet or an idea when a response will be available?

Thanks

Philip

I am really sorry we are working through all the scenarios today to make sure we give accurate information to everyone

@chirst do you have an update on when this will be available?
Thanks

@chirst @snicholas Sorry to chase but is there a timescale for when this information will be available?

@philip As you would expect we have received a number of queries similar to yours. Our policy area is working on a general response which I hope will cover your question and those of other developers. Apologies for the delay.

Nigel Preece

Hi there,
I just want to make sure that the general response has not been already posted elsewhere, right?

I’m waiting for this answer as well. And depending on the course of action to be decided, the impact on our code will be big. Given that our due date for PSCs is the 30th of this month, it would be nice to have the answer at least one week before that.
Thanks

@paulom No it hasn’t. I have chased.

Apologies

Nigel Preece

I see that some guidance has been issued on this under thread http://xmlforum.aws.chdev.org/t/confirmation-statement-guidance/121.

I note that this states that Companies House’s electronic system cannot cope with the case where any of the statements start and cease in the same confirmation period. Does this mean that if a company has three PSCs and these have statements that come and go such that if one PSC has an existing statement at the start of the confirmation period and this is ceased but then a new statement (of the same type or different) arises against another PSC can these be included in the same confirmation statement submitted electronically?

In addition can an electronically submitted confirmation statement include four separate new PSC statement notifications?

One more issue can an electronically submitted confirmation statement include where a company has a company statement at the beginning of the confirmation period and this is then ended and replaced by the other company statement during the period. Eg for the confirmation period from 1 July 2016 to 30 June 2017 the company has since 6 April 2016 had the not completed its review company statement and then on 18 July 2016 this statement ceased and was replaced by the company statement that the company had no PSCs can this be submitted on one confirmation statement?

Advice from our policy department:
Confirmation statement is not like the annual return in that it is more flexible. With confirmation statement you pay once for that period (year) with the first confirmation you file, then you can submit as many as you like for the rest of that period free of charge. You cannot submit more than one with the same confirmation date but you can submit as many as you like for that confirmation period.

There is no requirement to input a date when you add a PSC statement, but the public register will output the date that the filing was registered. This may not match the date that the statement was entered in the company’s register so you would need to submit a confirmation statement on the date a PSC statement was added to the PSC register to ensure it is shows on the public register with the correct date. You would then need to submit another confirmation statement to withdraw that statement when it no longer applies. The law does require a date for the withdrawal of a statement, but our system will not allow a statement withdrawal date before the statement was added to the register. You should be mindful of this when submitting confirmation statement(s).

You can have 4 person level PSC statement notifications on a single confirmation statement.

Thank you for getting the reply, however I am still not clear on what can be included in one electronically submitted confirmation statement. To help can you/the policy team consider the below examples and advise on each:

Example 1
06/04/2016 three unknown PSCs identified and this is entered on the PSC register
08/12/2016 two of these are withdrawn and the full confirmed PSC details for the PSCs is entered on the register
09/06/2017 the third unknown PSC is withdrawn and an unconfirmed PSC statement is entered

One confirmation statement dated 01/07/2016 is submitted electronically which has the three unknown PSC statements included

One confirmation statement dated 01/07/2017 covering the period from 02/07/2016 to 01/07/2017 is then submitted electronically with the three unknown PSC statement withdrawals and the unconfirmed PSC statement notification.

Please confirm that the above is correct in respect of electronic submissions.

Example 2
06/04/2016 General company statement that company has not finished investigating to see if there are any PSCs is entered
09/09/2016 Above general statement is withdrawn and replaced with the general company statement that the company has no PSCs

Confirmation statement dated 31/07/2016 is submitted electronically with the not finished investigating company statement notification

Confirmation statement dated 31/07/2017 is submitted electronically with the not finished investigating statement withdrawal and no PSCs company statement notification.

Please confirm that the above is correct in respect of electronic submissions.

HI
Will get our policy team to look at each example for you and get you answers to each.
thanks

Hi,

You’re correct in the two examples you set out above.

Thanks

Hi @chirst and @snicholas. Between all the examples & responses on this forum to this discussion, I have to say I am well and truly LOST with regard to when it’s acceptable for PSC events to be ‘saved up’ and reported in a once-a-year confirmation statement, and when it’s required for other PSC events to be filed on a confirmation statement on the day that they happen.

Rather than in a policy statement, has Companies House set this out plainly somewhere per PSC event, so that there’s no room for miss-interpretation?

Hello PJ,

Apologies for delay in responding - I will discuss this with colleagues on the team to see if we have anything suitable.

SDN

Hello PJ,

There is no requirement for PSC changes to be filed via a confirmation statement on the day that they happen, they are made in the next confirmation statement.

If the company elects to hold their PSC register with us however, then it becomes event driven.

In this instance, changes will not be made via the confirmation statement, but via the appropriate PSC forms.

I hope this clarifies.

SDN