In addition, from 30 June 2016, details in the PSC register will need to be filed with Companies House at least annually on a confirmation statement. Confirmation statements replace annual returns from June 2016. Once on file at Companies House, the details will be publicly available there in person or through an online company search, in the same way as other company information.
The company’s officers (directors and company secretary, if there is one) have a statutory duty to ensure that people with significant control and registrable entities are identified, and their details are confirmed if necessary and entered in the company’s PSC register. If there are no PSCs or registrable entities, the register must note this.
If the company is satisfied it has no PSCs or registrable legal entities – which is likely to be the case for most voluntary sector companies limited by guarantee – there must nevertheless be a register and it must contain a statement with the exact wording “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.”
Where there are no PSCs or RLEs, the company has a statutory duty to keep the situation under review, in case it changes. For example, a company with a small number of members may not have any PSCs as long as it has four or more members – but it the number drops below four, the remaining members will all be PSCs under condition ii.
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