A Guide to People with Significant Control (PSCs) & ID Verification

Identify People With Significant Control Using 5 Conditions

Companies are required to identify all people with significant control by testing them against the five conditions below. This legal requirement applies to all limited companies and limited liability partnerships (LLPs), and eligible Scottish partnerships.

The Five Conditions for Determining Significant Influence or Control

An individual is a PSC if they meet any of the following conditions, directly or indirectly:

• Shares: Holds more than 25% of the company’s shares.
• Voting Rights: Holds more than 25% of the company’s voting rights.
• Director Appointments: Holds the right to appoint or remove a majority of the board of directors.
• Significant Influence or Control: Individuals who have the right to exercise, or actually exercise, significant influence or control over a company are considered PSCs, even if they don’t meet the share, voting, or appointment thresholds.
• Trusts and Partnerships: Controls a trust or firm which itself would meet one of the first four conditions.

Understanding Indirect Control and Relevant Legal Entities (RLEs)

Control can be held directly by an individual or indirectly through a chain of other companies. If another company controls your company and meets the PSC conditions, it is classified as a Relevant Legal Entity (RLE).

List an RLE on your register instead of its individual owners, provided it is the first UK-registered legal entity in the ownership chain. If the controlling company is foreign and not on a specified regulated market, you must “look through” it to identify the ultimate individual PSCs. Identifying these key people is a fundamental requirement.

How Control is Measured in Percentage Bands

When you register a PSC, the company must state the nature of its control using specific percentage bands for shares or voting rights. Companies House requires one of the following three bands:

• Over 25% up to 50%
• Over 50% to less than 75%
• 75% or more

Two Steps to Register and Update Limited Company PSC Information With Companies House

Your company must identify its people with significant control and provide their details directly to Companies House. The process involves mandatory identity verification, gathering specific details, and filing the correct forms within strict deadlines.

Step 1: Complete Identity Verification and Gather PSC Data

The Economic Crime and Corporate Transparency Act 2023 introduced mandatory identity verification for every PSC. The act ensures the public register is accurate by requiring people with significant control (PSCs) verify their identity and receive a unique Companies House personal code.

Verifying your identity is a one-time ID verification process. There are two ways to complete it:

1. Directly with GOV.UK: Use the GOV.UK One Login service. This digital process is free and takes minutes. You will need a photo ID, such as a biometric passport or a UK driving licence.
2. Through an ACSP: An Authorised Corporate Service Provider (ACSP), like Your Company Formations, performs identity checks on your behalf.

After verifying your identity, you receive a Companies House personal code, which must be provided when you are registered as a PSC.

Mandatory checks began on 18 November 2025.

• New PSCs: Must complete verification before or shortly after their appointment.
• Existing PSCs: Have a transition period until 18 November 2026.

Next, gather the required PSC information. For each individual with significant control, you must provide these personal details:

• Full name and date of birth
• Nationality and country of residence
• Service address and usual residential address
• The date they became a PSC
• The nature of their control (which of the five conditions for significant control they meet)
• Their percentage band for shares or voting rights (this includes voting rights)

Step 2: File the Correct Form with Companies House

You must update your PSC register within 14 days of confirming a change. Your company no longer needs to maintain a local PSC register at its registered office; all information on Companies House must be up to date.

Select the appropriate form to register or update a PSC:

• PSC01: Register a new individual PSC.
• PSC02: Register a new Relevant Legal Entity (RLE).
• PSC04: Change an existing individual PSC’s details.
• PSC07: Notify Companies House that someone is no longer a PSC.
• PSC08: State that the company has no PSCs or is still investigating.

When you register a person as a psc, send their personal code to Companies House as proof of verification. Please note that Companies House checks this information for accuracy each year when you file your confirmation statement.

What to Do If Your Company Doesn’t Have Any PSCs

The PSC register cannot be left blank. If your limited company doesn’t have any PSCs, or if you are still taking steps to identify them, you must file a statement with Companies House to explain the situation. For example, you might state: “The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company.”

Penalties for Failing to Comply with PSC Rules

Companies House and UK law enforcement treat non-compliance with identity verification requirements as a serious issue. Failing to meet your obligations is a criminal offence for both the company and its officers.

Criminal Offences and Financial Penalties for Non-Compliance

If a company fails to take reasonable steps to identify its PSCs or does not keep the register updated, it faces an uncapped fine. Directors and other officers responsible for the failure are also personally liable.

An individual who fails to provide PSC information when requested, or knowingly provides false information, commits a criminal offence. The penalty is also an unlimited fine or up to two years in prison.

Civil Consequences: How Restriction Notices Work

A company can impose a Restriction Notice on shares if a shareholder fails to comply with a formal request for PSC information. The notice effectively freezes the shareholder’s interest, resulting in:

• Any transfer of the interest is legally void.
• The shareholder cannot exercise rights, such as voting.
• The company makes no payments, like dividends, and issues no further shares related to the interest.

How PSC Rules Differ for LLPs and Partnerships

While the PSC regime applies to most UK corporate entities, including companies and Limited Liability Partnerships (LLPs), the governing legislation ensures the rules are tailored to suit different business structures.

PSC Requirements for Limited Liability Partnerships (LLPs)

LLPs use modified conditions to identify their people with significant control (PSCs). According to the Limited Liability Partnerships (Application of Companies Act 2006) person has significant control over an LLP if they hold rights to more than 25% of the surplus assets on a winding-up, hold more than 25% of the LLP voting rights, or hold the right to appoint or remove a majority of the persons entitled to manage the LLP.

PSC Requirements for Scottish Limited Partnerships

Since 2017, UK law has required Eligible Scottish Partnerships to identify and report PSC information. Like other entities, they must determine who has significant control. A PSC is often the general partner or any limited partner who is entitled to more than 25% of the partnership’s surplus assets or profits.