Why an absent PSC is a problem for lenders
Lenders are required by AML regulations to identify and verify the beneficial ownership of any company they lend to. A company with no PSC registered at Companies House either has no one with a controlling interest (which is itself unusual) or has failed to make the legally required filing. Either scenario is a compliance problem.
Most lenders will decline or suspend an application until the PSC register is compliant. Unlike some other adverse circumstances that require negotiation or specialist lenders, the absence of a PSC registration is usually a straightforward administrative fix that should be resolved before approaching any lender.
How to resolve a missing PSC registration
If your company genuinely has individuals or entities who own or control more than 25% of shares or voting rights, they must be registered as PSCs at Companies House using form PSC01 (for individuals) or PSC02 (for relevant legal entities). This can be filed online through Companies House directly or through your company accountant or solicitor.
If your company structure genuinely means no single individual holds more than 25%, it is still possible to have no general PSC. In this case, the company should file a confirmation that it has no PSC or that it is exempt. The register must be explicitly completed rather than left blank.
- File PSC information immediately if not already done
- Use form PSC01 for individual PSCs or PSC02 for corporate PSCs
- Confirm 'no PSC' on the register if ownership is genuinely distributed below 25% each
- Ensure the Companies House PSC register matches your company's internal PSC register
- Inconsistencies between internal and filed PSC records also raise compliance concerns
Frequently Asked Questions
What is a Person of Significant Control?
A PSC is an individual (or relevant legal entity) that owns more than 25% of a company's shares, controls more than 25% of voting rights, has the right to appoint or remove a majority of directors, or otherwise exercises significant influence or control over the company.
What is the penalty for not having a registered PSC?
Failure to maintain and file PSC information is a criminal offence under the Companies Act 2006. The company and each officer in default can be fined. In practice, enforcement is gradual, but the reputational and practical consequences of non-compliance are immediate when any regulated party (lender, bank, accountant) checks your filings.
How quickly can I fix a missing PSC registration?
PSC filings can be made online at Companies House within minutes. They are typically reflected on the public register within 24 hours. Resolving this issue is one of the quickest fixes available and should be done before any finance application is made.