UK companies which are subject to the rules are required to maintain a register of people with significant control over the company and are required to report this information annually to Companies House via their confirmation statement.
Certain entities which are currently exempt from the regime, most notably those subject to the disclosure requirements of the Financial Conduct Authority's Disclosure and Transparency Rules, such as companies listed on the London Stock Exchange main market and Alternative Investment Market, may now be required to keep a PSC register. Those which are traded on an European Economic Area specified market will still be exempt. Active Scottish Limited Partnerships and General Scottish Partnerships will also be brought within the reporting regime.
All companies and partnerships keeping a PSC register will be required to update the register within 14 days of any change to its PSC and report the changes to the Registrar of Companies within 14 days of making such change via new forms being introduced by Companies House.
Companies and partnerships falling within the regime for the first time may need to devote significant time to the process of identifying and recording their PSCs in time for the June deadline. The vast majority are likely to find this a fairly straightforward process but those with complicated structures may need more time and assistance to ensure they comply with the new rules.
Pamela Laird is a corporate law expert at Pinsent Masons, the law firm behind Out-Law.com