PSC Register Mistakes That Trigger CH Queries

Companies House issued 234 civil financial penalties in the first six months of the new regime, and PSC errors made up a meaningful share. These are the mistakes that actually get flagged.

What the PSC register is meant to capture

A Person with Significant Control meets one or more of five conditions under Part 21A of the Companies Act 2006: more than 25% of shares; more than 25% of voting rights; the right to appoint or remove a majority of directors; significant influence or control; or the same exercised through a trust or firm without legal personality. The bands you record are 'more than 25% up to 50%', 'more than 50% up to 75%', and '75% or more'.

The register sits behind nine forms, PSC01 through PSC09, covering individuals, Relevant Legal Entities, other registrable persons, changes, cessations, additional statements and withdrawals. Updates go to Companies House within 14 days of the company's own register being updated, which itself has 14 days from the change. So 28 days, end to end.

Wrong nature-of-control codes

Single biggest cause of a Companies House query. The wording matters. 'Ownership of shares — more than 25% but not more than 50%' is the prescribed phrasing for the lowest band. 'Ownership of shares — 25% to 50%' looks identical but isn't, and the system has tightened on exact matches. Experienced filers still trip on this.

The other classic: confusing voting rights with shares. A founder with non-voting growth shares may not be a PSC under condition (i) at all, while a minority preference shareholder with veto rights may be one under condition (iii) or (iv). Read the articles before you fill in the form.

Missing or incorrect date of becoming a PSC

The 'date became a PSC' for a company formed pre-6 April 2016 is 6 April 2016, not the incorporation date. For companies formed after, it's the date of the triggering event. A share allotment that pushes a holder over 25% creates a new PSC, and the date is the date of allotment, not the date you spotted it.

When circumstances change (say, a share issue dilutes a PSC below 25%) you file PSC07 to cease, not PSC04 to change. PSC04 is for a change in the existing PSC's details: band moved up, address changed. Using the wrong form gets rejected.

Confusing shareholders with PSCs

Two siblings each holding 30% of the shares. Both are PSCs. We see firms record only the eldest 'because they speak for the family'. That's wrong, and it's a false statement. Each individual is tested against the conditions independently.

Conversely, a 60% shareholder who has signed a binding voting agreement giving control to a 20% shareholder may not be the only PSC. The 20% holder may also qualify under condition (ii) or (iv). The register is about control, not the share register.

Trust and corporate PSC pitfalls

Two traps here.

First, a Relevant Legal Entity is only registrable if it's UK-incorporated and itself keeps a PSC register (or is exempt as a listed entity). A BVI holdco doesn't qualify as an RLE; you look through to the ultimate individuals. We've seen firms record a Jersey parent on PSC02 and end up restating to PSC01s for the underlying beneficial owners.

Second, family trusts. The trustees collectively are the PSC if the trust holds the shares, and the nature of control is the trust condition, not the shareholding condition. If a settlor or protector exercises significant influence over the trust, they may also be a separate PSC. This is the area Companies House queries most often because the registers don't match the trust deed.

How to correct a filed PSC entry

If the entry is wrong you can't 'edit' a prior filing; you file the correcting form. PSC09 withdraws a statement that was incorrect when made. PSC07 ends a PSC who was correctly recorded but has since ceased. PSC04/05/06 amends a current PSC's details. PSC08 adds an additional statement (typically 'investigation ongoing'). The CS01 then confirms the corrected position as at the confirmation date.

One persistent error: marking PSC details 'confirmed' on the CS01 when no one has actually reconfirmed them. The CS01 confirms data is up to date; it doesn't update it. If something has changed since the last review, file the change form first, then the CS01. Our guide to what a confirmation statement is and when it is due covers the sequencing.

Avoiding repeat queries from Companies House

From 18 November 2025, every PSC must be ID-verified — see our walkthrough of how Companies House ID verification under the ECCT Act works. An unverified PSC is the next big driver of query letters, on top of the existing wording issues.

A few habits that cut queries to almost zero:

• Use the exact prescribed nature-of-control wording, copied from the Companies House schedule, not paraphrased.
• Reconcile the PSC register against the share register and articles at every CS01. Actually reconcile, don't tick a box.
• Never leave 'details not yet confirmed' as a permanent state. It's intended for live investigations, with a deadline.
• Get PSC verification done in the same sweep as director verification, not as a separate project.

Knowingly or recklessly filing a false statement is now an offence under s.1112A CA 2006, and the financial penalty ceiling is £10,000 per breach. The 'we always do it like that' defence has run its course.