This Content Was Last Updated on April 18, 2020 by Jessica Garbett
Companies House introduced the new annual Confirmation Statement (CS01) in April 2016. It replaced the old Annual Returns (AR01), which directors of more established limited companies will probably remember.
Whitefield Tax clients seem to have adapted to the “new” filing requirements very well. There still seems to be some confusion however around the Persons with Significant Control (PSC) register, which we advised would be a legal requirement from April 2016. Here is the guidance which has been on our website since the rule was introduced:
Practical: Maintaining a PSC register
The introduction of the PSC register was part of a Europe wide drive against Anti Money Laundering (AML), and its intention is to maintain a record of the beneficial owners of each and every company. The register must be kept up to date by law, and any changes to the PSC’s must be recorded within 14 days of the change, along with an update to the Companies House online record.
The Fifth EU Anti Money Laundering Directive (5MLD) came into effect on 10th January 2020, and it imposes new duties on accountants to not only check the PSC register of all clients, but also to report any discrepancies to Companies House.
In response to this directive, Whitefield Tax will, as part of the year end accounts process, request sight of each company’s PSC register. This can be in the form of a copy of a physical register (spread sheet/hand written record/word document etc), or you can let us have the extracted details via a web form:
The register will be checked to (a) the Companies House online record (b) our own permanent notes record (where we record the details of the company and its officers/shareholders). If we come across any discrepancies, we are legally required to report these to Companies House. If the discrepancies are of a cosmetic or minor nature, we will help you to correct the register, and a report will not become necessary. Please help us to help you stay compliant, by addressing any difficulties with this early on. We will be happy to help you to put your register together if you find any of it confusing.