What UK Companies Need to Know About the Updated PSC Guidance (and Why You Ignore It at Your Peril)
On 19 November 2025, the UK government quietly released updated summary guidance on the register of people with significant control (PSC). It did not come with fireworks, a media blitz or a moral crusade — just the usual reminder that transparency still matters, and Companies House would quite like to know who actually owns your business.
For those building FinTechs, scaling regulated firms, or simply trying to maintain a tidy compliance profile, this update is worth your attention. The rules have not fundamentally changed, but expectations have sharpened, timelines remain tight, and the criminal penalties remain exactly as motivational as ever.
Here’s the distilled version — minus the bureaucratic padding — and with a practical lens for real companies, not theoretical textbook ones.
Why the PSC Register Exists (and Why You Can’t Pretend It Doesn’t)
The PSC register is designed to make UK companies’ ownership transparent. In practice, it does three things:
Helps investors understand who really controls a company.
Helps law enforcement trace beneficial ownership — particularly useful when someone’s shell company in Croydon starts sending money to a trust in the British Virgin Islands “for reasons”.
Helps keep the UK’s corporate system from being used for money laundering, tax evasion or other creative entrepreneurship.
Companies House will publish the information (unless the individual qualifies for protection due to genuine risk of violence — not simply a fear of spam emails).
What Companies Must Actually Do
An officer of every UK company — which could mean you — must:
Identify the PSCs (more than 25% shares; more than 25% voting rights; right to appoint/remove the majority of directors; or the more nuanced “significant influence or control”).
Confirm their details with the individual.
Submit the details to Companies House within 14 days.
Update Companies House within 14 days if anything changes.
Confirm accuracy annually if nothing has changed.
Yes, 14 days. Not “next quarter”, not “when we get to it”, and definitely not “after the fundraising closes”.
Who Counts as a PSC? The Five Conditions
Most companies will deal with the first three:
Over 25% shareholding
Over 25% voting rights
Right to appoint/remove a majority of directors
Two additional conditions apply when the structure gets more interesting:
Significant influence or control (the catch-all for the person who controls everything but somehow owns nothing).
Influence exercised through a trust or firm controlled by an individual.
And yes — indirect holdings count. A 30% stake held through a holding company still counts as control by the individual behind that holding company.
The Information You Must Collect
Before reporting, you must confirm with the PSC:
Name
Date of birth
Nationality
Usual residential address
Service address
Country/region of residence
Date they became a PSC
Which PSC conditions they meet
The exact share/voting threshold (25–50%, 50–75%, or 75%+)
The usual residential address will not be made public, but Companies House needs it anyway. Think of it as a trust exercise.
When PSCs Don’t Cooperate
If a PSC refuses to provide information without reasonable excuse, that is a criminal offence.
Companies can even place restrictions on the PSC’s shares or voting rights until they comply — essentially putting their equity into “time out”. Not a popular move, but an effective one.
Keeping the PSC Register Updated
Everything must be updated within 14 days:
A new PSC is identified
A PSC’s details change
A PSC ceases to be a PSC
A PSC fails to respond to a notice
A PSC finally does respond to a notice
A restrictions notice is issued or withdrawn
The PSC register must never be blank. If details are not available, the company must file the appropriate “we are still trying” statements — Companies House will not accept an empty page.
What Happens If You Don’t Comply
Failure to:
identify PSCs,
obtain the information,
submit it, or
keep it updated
…can result in fines or up to two years in prison.
And no, “I didn’t know” is not a reasonable excuse — not least because this blog now exists.
What This Means for FinTech Start-ups and Scaling Firms
For early-stage companies with evolving cap tables, rapid fundraising cycles, and shifting board compositions, the PSC register is a governance process that must sit alongside your cap table management, share issuances and investor reporting.
The guidance reinforces:
Timeliness is non-negotiable — keep your lawyers, accountants and governance advisers aligned.
Hidden control is still control — nominee arrangements, shareholder agreements and power dynamics must all be assessed.
Poor record-keeping is a regulatory liability — and potential investors see PSC accuracy as a proxy for broader governance health.
In short: clean PSCs, clean corporate hygiene.
How AnyAccount Helps
At AnyAccount Ltd, we support FinTech start-ups and scaling businesses with:
PSC identification mapping
Cap table verification
Governance structures aligned to UK company law
Companies House filings and ongoing updates
End-to-end compliance frameworks for regulated entities
If you’d prefer not to test the limits of the Companies Act — or HMRC’s patience — speak to us. We can help you implement a PSC governance process that is accurate, compliant and integrated into your broader regulatory infrastructure.
