Updating PSC Information After Incorporation

After incorporating a company in England and Wales, one of the ongoing legal obligations under UK company law is to keep the register of Persons with Significant Control (PSCs) up to date. A PSC is an individual or legal entity that owns or controls your company, typically by holding a certain level of shareholding or voting rights, having the right to appoint or remove directors, or otherwise exerting significant influence. If any details about your PSCs change after incorporation, the company must update both its own PSC register and the central public PSC register held by Companies House. Failure to comply can lead to civil penalties and criminal offences for false or late reporting.

This article explains the legal requirements and practical steps for updating PSC information after incorporation, including what must be updated, the time limits for filing changes, the process for reporting to Companies House, and common questions and considerations.

What Is a PSC and Why It Matters

A Person with Significant Control (PSC) is an individual or legal entity that meets one or more statutory conditions indicating effective ownership or control of a company. Typical criteria include:

• Owning more than 25% of shares in the company.
• Holding more than 25% of voting rights.
• Having the right to appoint or remove a majority of directors.
• Exercising significant influence or control over a company's decisions.

Maintaining accurate PSC information promotes transparency in corporate ownership, informs creditors and third parties, and supports legal and regulatory checks for due diligence. The Companies Act 2006 and secondary legislation require accurate PSC data to be held on both the company's internal PSC register and the central electronic register at Companies House.

Legal Duties to Update PSC Information

Companies must ensure that PSC information remains current:

• Update the company's own PSC register within 14 days of a change occurring or being confirmed.
• Notify Companies House with the updated PSC information within a further 14 days after updating the company's internal register.

This means from the time the company becomes aware of a change, it has up to 28 days in total to reflect that change on the central register.

Keeping PSC data accurate on the public register is legally required; failure to update or knowingly filing incorrect information is a criminal offence that may incur fines or more serious sanctions.

What Types of Changes Must Be Updated

After incorporation, changes that must be updated include:

• Personal details of a PSC (name, nationality, usual residence country, service address).
• Changes in shareholding or voting rights that affect whether a person remains a PSC or becomes one.
• Date that a person becomes or ceases to be a PSC.
• Changes to the nature of control (for example, moving from one control threshold to another).

Both changes in factual information and changes in legal status (such as a PSC ceasing to meet qualifying criteria) must be recorded and reported promptly.

Step‑by‑Step: How to Update PSC Information

1. Confirm the Change and Gather Accurate Information

Before updating any register, the company should confirm the change with the PSC or the legal entity concerned. This may involve requesting updated information directly from the individual or entity. If a PSC fails to provide required details after reasonable steps have been taken, the company must record this fact in its register and may need to serve statutory notices to obtain information.

2. Update the Company's Internal PSC Register

Once the change is confirmed:

• Enter the updated information in the company's own PSC register.
• If the information cannot yet be confirmed in full, record when the existing information became incorrect and the steps being taken to obtain accurate information.
• Make the update within 14 days of becoming aware of the change.

The internal register must be kept available for inspection by members and other authorised persons.

3. Notify Companies House

After updating the internal register:

• Submit the appropriate form to Companies House within 14 days of updating the internal register.
• This can usually be done through the WebFiling service using your company's authentication code.
• The relevant PSC forms include:
  • PSC01 – for newly designated PSCs.
  • PSC04 – for changes to existing PSC details.
  • PSC07 – for PSCs ceasing to be registrable.

Online filing is generally quicker and more efficient than paper forms.

4. Ensure Annual Confirmation

Even if no changes have occurred, companies must confirm that PSC information remains correct when filing their annual confirmation statement with Companies House. This statement confirms that all information held about PSCs on the public register is up to date.

Time Limits and Practical Considerations

Deadlines for Filing Changes

• 14 days to update the company's own PSC register after a change.
• 14 days to notify Companies House after updating the internal register.
  This means companies have up to 28 days from the date of the event to make the change public.

Late filings can attract penalties and may create legal exposure for directors and officers, depending on the circumstances.

Identity Verification Requirements

From November 2025, Companies House introduced identity verification requirements for PSCs and directors under reforms to strengthen transparency and prevent fraud. PSCs may need to verify their identity to file or update their information, and these new procedures should be taken into account when updating details.

Protection of Sensitive Information

Individual PSCs who are at risk of violence or intimidation may apply to have their information protected from public disclosure, subject to strict criteria and approval. Companies must not disclose protected personal data.

Common Scenarios Requiring Updates

Change in Shareholding

If a PSC's shareholding falls below a threshold (e.g., from more than 25% to below that level), the company must update its internal register and notify Companies House that the person no longer has that status and provide the date of the change.

Change of Personal Information

Changes in a PSC's name, nationality or service address are updated using PSC04 forms. These updates must be reflected both in the internal register and the public register.

New PSC Identified

If a current shareholder or investor acquires control qualifying for PSC status, the company must add the person to its internal register and notify Companies House using PSC01, including details of when the person became a PSC.

Risks of Non‑Compliance

Failing to keep PSC information accurate carries significant legal risks:

• Criminal offences for providing false information or failing to comply with notices.
• Financial penalties for late or incorrect filings.
• Reputational harm and practical obstacles in business operations due to inaccurate public records.

Companies should monitor shareholder changes and control arrangements proactively to avoid regulatory issues.

Key Takeaways

Updating PSC information after incorporation is a key ongoing compliance obligation for companies in England and Wales. Companies must update their internal PSC register within 14 days of discovering a change, and then notify Companies House within a further 14 days, ensuring the public register is accurate and current. Changes include updates to personal details, modifications to control thresholds, and additions or removals of PSCs. Reforms to identity verification and protections for sensitive information add further considerations. Timely reporting supports transparency, protects legal compliance, and avoids penalties.