In a push for transparency in company ownership, an obligation on companies to identify and maintain a register of People with Significant Control (PSCs) came into effect from 6 April 2016.  Companies should already be making efforts to identify any PSC and to confirm certain specified information for each one identified.  Even if this process has not been completed yet, the PSC register cannot be blank and must make a record that the company is in the process of carrying out a search or waiting for the information to be confirmed.

This currently non-public exercise is important as, with effect from 30 June 2016, companies will be required to maintain a public PSC register at Companies House, with certain specified information given for each identified PSC.

Any trustees or unincorporated bodies, such as partnerships, identified as having significant control over a company will also need to be registered as PSCs, and the information obligations can even extend to beneficiaries of trusts if they have significant control over the trust.

The non-statutory PSC guidance is over 80 pages long and has complex requirements, but with potential criminal liability for a failure to comply with the obligations, companies should take these obligations seriously and seek professional advice if necessary.