Following our earlier blog piece on the new requirement for UK limited companies (including pension trustee and employee benefit trust companies) to identify their “people with significant control” (PSCs), today is the day from which this information must start being made public at Companies House.

The first step is to identify your PSCs (if you have not already done so).  Then, when your company’s next confirmation statement (which replaces the annual return) is due, you must file this information at Companies House.

In this regard it is worth noting that the annual return process is changing.  Previously, all companies were required to file an annual return which detailed things like the officers, registered office address, shareholders and share capital of the company.  From today, the annual return is replaced with the confirmation statement (form CS01) which is a declaration that there have been no changes to the company data held by Companies House since the last statement was filed or that all changes have been reported at the time they took place. If not, such changes will need to be submitted with the confirmation statement.  Your company’s PSCs will need to be notified to Companies House alongside this confirmation statement.

Confirmation statements must be made at least once a year, but the company may choose to make a statement more regularly.  If the company chooses a one year period between confirmation statements, they must be filed no later than 14 days from the end of the one year period.

Pension trustee companies and employee benefit trust companies should ensure they are clear about who will submit their confirmation statement and PSC information (this might be group secretariat, the scheme secretary, the pensions manager or a professional adviser) and that the statement is added to the scheme’s annual business plan to ensure continued compliance. A pension trustee company’s PSC register will not ordinarily change but special care should be taken if there has been any corporate or restructuring activity where the trustee company is part of a group of companies. Failure to maintain a PSC register or submit a confirmation statement to Companies House on time could result in the trustee and/or the trustee directors being liable to criminal sanctions and/or a fine.

If you would like to discuss how to identify the PSCs of your trustee company, or how to go about filing this information at Companies House, please get in touch with your usual Squire Patton Boggs contact.