The PSC regime has been in place since 2016, but it remains one of the most-mishandled areas of UK company secretarial work. Beneficial ownership changes are not always obvious - a share transfer between family members, a new corporate shareholder taking 25% plus one share, a relevant legal entity replacing a previous PSC - and the wrong form filed at the wrong time produces a register that does not match the underlying reality. ECCTA has sharpened enforcement here too, so the cost of getting it wrong is rising.
The five PSC forms and what each does
The PSC family of forms covers the lifecycle of a PSC entry on the register. Each has a specific trigger.
- PSC01: notice of an individual person with significant control
- PSC02: notice of a relevant legal entity (RLE) with significant control
- PSC03: notice of an other registrable person (rare - used for ORPs)
- PSC04: change of details of an existing individual PSC
- PSC05: change of details of an existing RLE PSC
- PSC07: notice of ceasing to be a PSC
- PSC08: notification that the company has no PSC
- PSC09: notification that the company has not yet identified its PSC
The two 14-day clocks that matter
The PSC regime runs on two consecutive 14-day windows that firms often conflate. First, the company has 14 days from becoming aware of a PSC change to update its own internal PSC register. Second, it has a further 14 days from updating the internal register to notify Companies House. That gives a maximum 28-day gap between the underlying event and the public register being correct. For practical purposes most firms file as soon as they update the internal register, treating the 14+14 as a single 28-day budget rather than two separate windows.
PSC01 in practice - individual PSCs
PSC01 is filed whenever a new individual meets one of the five PSC conditions: more than 25% of shares, more than 25% of voting rights, the right to appoint or remove a majority of the board, the right to exercise significant influence or control, or significant influence or control over a trust or firm whose trustees/members meet any of the other conditions. The form captures full name, date of birth, nationality, country of usual residence, service address, usual residential address, and the date the person became a PSC. The percentages are filed within bands (over 25% to 50%, over 50% to 75%, over 75%), not exact figures.
PSC02 - relevant legal entities
PSC02 is for corporate-shareholder structures where a UK company or other RLE sits in the ownership chain and is itself subject to PSC disclosure or equivalent transparency requirements. The RLE must be both registrable (it meets a PSC condition over the subsidiary) and relevant (it is itself subject to its own PSC regime or to broadly equivalent disclosure under DTR5 or similar). If the corporate shareholder is offshore and not subject to equivalent disclosure, you do not file PSC02 - you look through to the ultimate beneficial owner and file PSC01 for that individual instead.
PSC04 - change of details
PSC04 covers detail changes for an existing individual PSC: name change, residential address change, service address change, nationality change, or a change in the nature of control (for example, crossing from the 25-50% band into the 50-75% band after a further share issue). The form does not replace the PSC; it updates them. A PSC who ceases entirely is removed via PSC07, not PSC04.
PSC07 - ceasing to be a PSC
PSC07 is filed when an existing PSC no longer meets any of the conditions: share transfer takes their holding below 25%, voting agreement ends, or the trust giving them significant influence is wound up. The form requires the date they ceased and the nature of control they previously held. If the company has no remaining PSCs after the cessation, PSC08 (no PSC) must follow.
The most common errors firms make
Three errors come up repeatedly. First: treating a share transfer between spouses as a non-event, when it actually triggers PSC07 for the transferor and PSC01 for the transferee. Second: filing PSC02 for an overseas corporate shareholder that is not subject to equivalent disclosure, when the correct route is to look through to the individual UBO. Third: forgetting to update the internal register before the Companies House filing - the internal register is a statutory record and a regulator can ask to see it.
How Accupe keeps the PSC picture clean
Accupe's Companies House integration pulls the current PSC entries for every client company. Compliance Radar flags discrepancies between the public register and any updated ownership data the firm holds, so the team can chase the underlying PSC form. The firm still files PSC01/02/04/07 via its existing software - Accupe does not file to Companies House - but the visibility layer means a PSC change spotted during a tax return engagement does not get parked and forgotten until the next confirmation statement.
Closing
The PSC forms are short. The judgement calls behind them are not. Get the trigger event right, file within the 14-day Companies House window, keep the internal register synchronised, and use a tool that surfaces drift between what the public register says and what the firm actually knows. That is the difference between a tidy practice and a backlog of late PSC notices that surface when a client tries to refinance.