PSC Register Explained: Who Counts and What Accountants Must File

Most accountants know the PSC register exists. Fewer can say with confidence exactly who has to be on it, how ownership bands are recorded, or what happens when a client's register falls out of date. With Companies House identity verification now live and enforcement tightening under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), getting the PSC register right is no longer a box-ticking exercise — it's a genuine compliance risk for clients and the firms advising them.

What is the PSC register?

The register of People with Significant Control is a statutory record every UK company (with limited exceptions, such as companies already subject to equivalent disclosure rules) must keep and file with Companies House. It exists to make company ownership transparent — showing who actually controls a company, not just who's named on paper as a shareholder or director.

Who counts as a PSC?

An individual is a Person with Significant Control if they meet any one of five conditions:

• Holding, directly or indirectly, more than 25% of the company's shares
• Holding, directly or indirectly, more than 25% of the company's voting rights
• Holding the right to appoint or remove a majority of the company's board of directors
• Otherwise having the right to exercise, or actually exercising, significant influence or control over the company — for example, by ensuring the company adopts the activities or policies the individual wants
• Having significant influence or control over a trust or firm that itself meets any of the first four conditions, where that trust or firm would itself be a PSC if it were an individual

A company can have more than one PSC, and in more complex ownership structures — trusts, partnerships, multi-layered corporate groups — working out exactly who qualifies is often the hardest part of the exercise, and is where accountants add real value beyond simply filing the form.

What has to be filed, and how

For each PSC, the company must record: full legal name, date of birth, nationality, country of residence, a service address (which is publicly visible) and a home address (which is withheld from public view), the date the individual's control began, and the nature of that control.

Ownership and voting rights aren't disclosed as exact percentages — they're recorded in bands: more than 25% up to 50%, more than 50% up to 75%, and 75% or more. This banding is a deliberate design choice, giving transparency about the scale of control without requiring companies to publish precise shareholding percentages.

The PSC register is updated as part of the annual confirmation statement (form CS01), but it isn't purely an annual exercise — companies must report a change in PSC details, or a change of PSC entirely, within 14 days of confirming the change has happened.

How this connects to identity verification

The PSC register doesn't exist in isolation from the wider ECCTA reforms. As we covered in our guide to Companies House identity verification, from 18 November 2026 every PSC (not just directors) of an existing UK company must have verified their identity with Companies House. In practice, this means the PSC register and the identity verification register increasingly work together: a company can have a technically accurate PSC entry that's still non-compliant if that individual hasn't completed identity verification. Firms reviewing client PSC registers ahead of the deadline should treat it as one combined exercise, not two separate ones.

It's also worth distinguishing the PSC register from the broader concept of beneficial ownership — PSC is the UK's specific statutory implementation of beneficial ownership transparency, with its own thresholds, bands and filing mechanics, sitting alongside similar (but not identical) regimes in other jurisdictions.

Penalties for getting it wrong

Non-compliance carries real teeth. Providing false information on the PSC register, or failing to comply with a notice requiring PSC information, is a criminal offence that can result in up to two years' imprisonment, an unlimited fine, or both, for the most serious cases. Lesser breaches — such as failing to keep the register up to date — can attract fixed penalty fines, with daily default fines for continuing non-compliance. Companies House also has powers to issue restrictions notices against shares or voting rights where a suspected PSC fails to respond to information requests, effectively freezing the ability to exercise those rights until the position is resolved.

A practical checklist for accountants and company secretarial teams

• Confirm every individual who meets any of the five PSC conditions is correctly recorded, including in complex trust, partnership or multi-entity ownership structures
• Check ownership bands are current — a shareholding that has crept from just under to just over a threshold needs the register updated within 14 days
• Cross-check PSC entries against identity verification status ahead of the 18 November 2026 deadline
• Build PSC register review into the annual confirmation statement process rather than treating it as an afterthought
• Flag to clients that "no PSC" is rarely the right answer for a functioning trading company — if no individual meets the tests, further investigation (and in some cases relevant legal entity or relevant trust disclosure) is usually required

FAQ

Can a company have no PSC at all?
In principle yes, but it's uncommon. If no individual meets the PSC conditions, the company still needs to actively confirm and record that no PSC exists — it can't simply leave the register blank.

Is the PSC register the same as identity verification?
No. The PSC register is about identifying and disclosing who controls a company. Identity verification is a separate requirement confirming that a named director or PSC is genuinely who they claim to be. From November 2026 both need to be in place together.

How quickly must PSC changes be reported?
Within 14 days of the company confirming the change has taken place, separate from the annual confirmation statement.

PSC compliance sits right at the intersection of company secretarial work and anti-money-laundering due diligence — an area of practice that's only getting more scrutiny. Learnsignal's CPD courses cover the wider AML and corporate transparency landscape UK accountants now need to navigate.