Since 2016, UK companies have had to keep a record of the people who own or control them. This is called a Person of Significant Control register, or PSC register. This register has to include individuals and legal entities who have major influence over the business. The Economic Crime and Corporate Transparency Act has added more verification and identification requirements. From 18th November 2025, there is a mandatory identity verification requirement for those individuals who are directors, members of Limited Liability Partnerships (LLPs), and registerable persons with significant control (PSCs). Companies will have to tell Companies House whenever there’s a change in who controls the company, and that information will still be publicly available online.

What is significant influence or control?

‍According to the new PSC Conditions, someone is considered a PSC in relation to a company if they have the right to, or are actually, exercising “significant influence or control”. This is a simple definition, limited to certain circumstances. Both “significant influence” and “control” are to be treated as alternatives when examining companies.

The government has anticipated confusion or any unique issues that have arisen and has released statutory guidance to help explain the conditions. This guidance can help legal professional define unique circumstances, such as Scottish partnerships, Societates Europaeae, or any other difficult situations.

Who is a person with significant control?‍

A PSC is a person who satisfies any of the following five conditions:

- The individual directly or indirectly holds more than 25% of the shares in the company;

- The individual directly or indirectly holds more than 25% of the voting rights in the company;

- The individual directly or indirectly holds the right to appoint/remove a majority of the board of directors of the company;

- The individual has the right to exercise, or does exercise, significant influence/control over the company;

- In situations where the company is controlled or owned by a trustor firm, which is not a legal entity and would satisfy one of the first four conditions if it were a person, the person has the right to exercise/does exercise significant influence/control over the activities of that trust or firm.

As illustrated, a PSC cannot be a legal entity, such as an LLP, and will always be a natural person.

What is a relevant legal entity?

‍A Relevant Legal Entity (RLE) is different from a PSC. A company or LLP is relevant where it satisfies one of the five PSC conditions listed above and either is subject to the UK PSC regime, or it has voting shares admitted to trading on regulated markets in the UK, EEA, or on specific markets in Switzerland, Japan, Israel, or the USA.

A RLE will need to be considered within the filings sent to Companies House if it is registerable in relation to that company. Where there is a chain of RLEs, the company needs to only consider the next UK company up on the chain, not the whole chain. Non-UK Companies are not subject to the new PSC Regime.

Key points for legal practitioners and clients to consider

When a company is examining who has control, an individual has to be able to ensure a company/trust/firm adopts activities that they desire. The control/significant influence does not have to be exercised by someone who wishes to gain economic benefits, just their desired direction for the company is enough. An individual can have this power and not use it; this does not change their status as a PSC. The existence of significant influence is enough to be considered one.

The right to exercise influence can be conferred in a variety of ways. Legal advisors need to consider what a company’s constitution says, the rights attached to shares and how this interacts with the shareholders, and any other agreements that interact with the company. Someone may qualify as a PSC if they have control and influence, even in the absence of any formally granted rights from a contract, agreement, or constitution. Altogether this forms a complex web that legal practitioners need to examine in detail, from the abstract soft power that individuals can exert, to the concrete hard power conferred through a constitution.