PSC Registers Under ECCTA 2023: The Compliance Time Bomb for UK Directors
ECCTA 2023 tightens PSC register requirements with new verification obligations. UK directors face personal liability for non-compliance. Here is what your Company Secretary must do now.
The Economic Crime and Corporate Transparency Act 2023 changed the rules on PSC (Persons with Significant Control) registers. Most Company Secretaries know this. Fewer have actually updated their processes. That gap between awareness and action is where personal director liability lives.
What Is a PSC Register Under ECCTA 2023?
A PSC register is the statutory record of every individual or entity that exercises significant control over a UK company. Under ECCTA 2023, Companies House now has expanded powers to verify, query, and reject PSC information. The Act introduces identity verification requirements for all registered persons and gives the Registrar authority to annotate or remove entries that fail verification. Non-compliance carries criminal penalties for directors and the company itself.
What Changed Under ECCTA 2023?
The changes are material, not cosmetic:
- Mandatory identity verification. Every PSC must verify their identity through an authorised identity service provider or an authorised corporate service provider.
- Companies House rejection powers. The Registrar can now refuse filings that contain unverified or inconsistent PSC data.
- Director personal liability. Directors who knowingly allow inaccurate PSC information to persist face criminal prosecution.
- Enhanced information sharing. Companies House can share PSC data with law enforcement agencies without a court order.
- Annual confirmation expansion. The confirmation statement now requires active verification that PSC data remains accurate, not just a tick-box confirmation.
Why Is This a Time Bomb?
Because most UK companies have not yet undergone identity verification for their PSCs. The transition period is closing, and companies that file without verified data will face rejections. A rejected filing means a missed deadline. A missed deadline means a penalty. A pattern of missed deadlines means a Companies House investigation.
The compounding risk:
- Filing rejections cascade into late filing penalties (£150 to £1,500 per instance)
- Unverified PSC data triggers enhanced scrutiny from the Registrar
- Director awareness (once informed of the issue, failure to act becomes wilful)
- Third-party reliance on PSC data creates contractual risk (M&A, banking, insurance)
What Must the Company Secretary Do Now?
The action plan is straightforward but urgent:
- Audit current PSC register against ECCTA requirements within 30 days.
- Initiate identity verification for all registered PSCs through an ACSP.
- Update internal processes to capture verification status changes in real time.
- Brief the board on personal liability implications (this protects directors' "reasonable steps" defence).
- Implement monitoring for any Companies House queries or annotations against the company.
How Does Simplif-i Handle PSC Compliance?
Simplif-i's Company Secretary module maintains the PSC register as a live, version-controlled record linked to identity verification status. When verification expires or is queried, the system alerts the Company Secretary and escalates to the board if action is not taken within the defined SLA. Filing deadlines are tracked automatically with pre-submission validation that catches errors before they reach Companies House.
At £49/month for the CoSec module, or £149/month for the full platform as a Founding Member, it costs less than one hour of a director's salary to eliminate personal criminal liability risk.
Frequently Asked Questions
When does mandatory identity verification come into force? The transition is phased, with full enforcement expected by Q4 2026. Companies filing now should already be verified to avoid rejection.
Who counts as a PSC? Any individual holding more than 25% of shares or voting rights, or exercising significant influence or control over the company.
Can a Company Secretary handle verification on behalf of PSCs? Yes, through an Authorised Corporate Service Provider (ACSP) arrangement.
What happens if a PSC refuses to verify? The company must file a PSC warning notice. Continued non-cooperation must be reported to Companies House.
Does Simplif-i integrate with Companies House filing? Yes. Direct API integration for confirmation statements, PSC notifications, and filing status tracking.
Compliance, simplif-i'd.
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