A FTSE250 Company Secretary writes...
“Please can you let me know how you are preparing to deal with “people with significant control” within the Small Business, Enterprise and Employment Act?
From 6 April 2016 virtually all UK companies will be required to maintain a Register of People with Significant Control (including dormant companies and group subsidiary companies) and from 30 June 2016 details of PSC registers will need to be filed with UK companies House at least once every year when annual filings are made.
Whilst some guidance notes have recently been released on the Gov.uk website (and further guidance is expected soon) what plans you have made or have you put any arrangements in place?
There is a free webinar from TMF Group on practical steps to take now and issues to consider which you can register for at webinar@tmf-group.com
Surprised that there are no comments on this one as it is pretty key! As a professional services firm acting for all sorts of companies including FTSE 100 we have some of this information already on UBOs as part of our KYC checks. Should be straightforward in most cases eg parent with wholly owned subsidiaries and family owned companies. For JV companies will need to do some work. For more complex group structures will need to send out notices to obtain or confirm the information; considering doing annual returns for more complex groups early ie before 30 June when PSC information has to submitted with the replacement of the annual return so it gives us more time to get the PSC information right, however there is the option of noting on the register that we are using reasonable efforts but do not have the information yet . Would be interested in others’ views.