The 7 most common PSC register mistakes accountants fix

The PSC (Persons with Significant Control) register has been mandatory since April 2016, but errors remain widespread. Companies House actively uses the register to investigate company ownership — and inaccuracies can lead to criminal liability, not just civil penalties.

1. Incorrectly applying the 25% threshold

The beneficial ownership threshold for PSC status is more than 25%, not 25% or more. A shareholder holding exactly 25% is not a PSC under this condition. However, they may still qualify under other conditions — voting rights, directorial influence, or other control mechanisms. Always assess all five PSC conditions, not just the share threshold.

2. Not registering indirect PSCs

A PSC does not need to own shares directly. If an individual controls a company that owns shares in another company, beneficial ownership passes through the chain. This is a common oversight in group structures — accountants sometimes register the holding company as the PSC rather than looking through to the individual.

3. Failing to notify within 14 days

Any change in PSC status must be notified to Companies House within 14 days of the company becoming aware of the change. This includes new PSCs arising from share transfers, changes in shareholding that cross the threshold, and changes in control arrangements.

⚠️Failure to keep the PSC register accurate is a criminal offence. Directors can be prosecuted — not merely fined — for knowingly providing false information or failing to take reasonable steps to investigate and record PSC status.

4. Not superseding old PSC entries

When a PSC ceases to be a PSC, their entry must be marked as ceased — not deleted. Companies House keeps a historical record. Filing a cessation notification (PSC07 or PSC08) is required within 14 days of the change.

5. Treating "exempt" PSCs incorrectly

Some entities are exempt from PSC registration — listed companies, certain financial institutions, and companies subject to their own regulatory disclosure requirements. Marking a PSC as exempt without proper grounds is an error. Always verify the exemption applies before using this filing option.

6. Incorrect nature of control descriptions

Companies House requires specific statutory descriptions of how control is exercised. These are prescribed categories — don't paraphrase or create bespoke descriptions. Using the wrong category is a technical inaccuracy on the public register.

7. Confusing PSC register with beneficial ownership

The PSC register captures those who control the company — it's not a complete beneficial ownership register for all purposes (e.g., HMRC trust registration or money laundering reporting). Make sure clients understand the distinction and that other reporting obligations may apply separately.