New PSC Reporting Obligations Now in Force

As charities will be aware, the PSC regime was introduced in April 2016. Since then, charities which are subject to the regime have been required to keep a register of PSCs and to submit this information to Companies House by way of the annual confirmation statement. However, the information about People with Significant Control (Amendment) Regulations 2017 have introduced new requirements which are effective from 26 June 2017.

What Are the New Reporting Requirements?

Rather than submitting information to Companies House via the annual confirmation statement, charities will now need to update their PSC register and report to Companies House on a continuous, event-driven basis. The process for recording changes to PSC status is now as follows:

• Charities must update their PSC register within 14 days of becoming aware of a change to their PSCs
• Within 14 days of updating their register, charities must then notify Companies House of when the change was made and what the change involved, using forms PSC01 to PSC09

Notification of Changes Occurring Since the Last Confirmation Statement

If a charity has updated its internal PSC register since it filed its last confirmation statement, then it will also need to notify Companies House of these changes immediately (as the 2017 Regulations included a very short deadline of 10 July 2017 which has already passed).

Non-Compliance

Charities should be aware that failure to comply with the notification obligations is a criminal offence.

Additional Organisations Now Subject to PSC Regime

The new Regulations have also brought additional types of organisations within the PSC regime, including unregistered companies.

If you need assistance in relation to any aspect of the PSC rules then our Charities team will be pleased to assist.

For further information please contact Con Alexander in our Charity Law team on 0117 314 5214.