We previously blogged about the forthcoming changes to the PSC regime. The government published the relevant legislation late on Friday, and the changes take effect from today!
So, what do you need to do, and when do you need to do it?
What: companies traded on AIM and NEX exchange must create and maintain a PSC register.
When: by 24 July 2017.
What: updating the PSC register following a change in circumstance.
When: within 14 days of the company having confirmed information.
What: filing changes to the PSC register at Companies House using form PSC01-09.
When: within 14 days of the change being made to the PSC register.
What: filing any changes to the PSC register since the company’s last confirmation statement.
When: within 14 days of 26 June 2017.
LLPs take note – equivalent provisions to the above have been implemented and will apply to you.
The separate regime for Scottish limited partnerships and those Scottish general partnerships with all corporate partners has also come into force.
What: these entities do not have to maintain their own internal PSC register but they do have to gather information about their PSCs and file that information at Companies House
When: within 14 days of whichever is the later of (i) 24 July 2017 and (ii) the entity having all the confirmed information. Going forward, changes to any filed information must be notified within 14 days
As you can see, the PSC regime has been widened to capture new entities, and the reporting regime has been significantly toughened. The register at Companies House should now contain an accurate, up to date record of the company’s PSC register. You may need to take action now – ask yourself:
- is the PSC register up to date?
- is the information contained in the last confirmation statement still accurate?
- if the company did not previously need a PSC register, does it need one now?
This post was written by Matthew Lappin. For further information, please contact:
Sophie Brookes, partner, Corporate
T: 0161 836 7823