Changes to the PSC regime

From 26 June 2017, all EU Member States must have in place central registers of beneficial ownership, under the provisions of the 4th Money Laundering Directive (Directive).

The UK put provisions in place ahead of the implementation date set by the Directive, with the effect that since 6th April 2016, UK companies and LLPs have been required to keep a register of persons with significant control (PSCs) over the entity. These persons may be individuals or corporate entities (known as relevant legal entitles (RLEs)) and may be the same as existing shareholders or may be different.

In order to meet with the remainder of the Directive requirements, a number of changes have now been made to the PSC regime, effective from 26 June

Entities subject to the regime Updating information A person becoming a PSC or RLE - for example, they acquire shares in a company and their ownership exceeds 25% of the company’s share capital for the first time.

A person ceasing to be a PSC or RLE - for example, they dispose of shares so that they now hold 25% or less in the company’s shares or voting rights.

Changes in specified details of a PSC or RLE - for example, a PSC changing their residential address or an RLE changing its name.

Changes to the nature of an existing PSC’s control over the company - for example, they acquire or dispose of shares, which takes them into different ‘shareholding brackets’.

Protection for PSC information

The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.