If you have been told you are a "person with significant control" (PSC) of a UK company and have received correspondence about needing to verify your identity at Companies House, this page answers the questions PSCs typically ask. The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced a mandatory identity-verification regime that applies to every natural-person director AND every natural-person PSC of every UK company. The verification became a legal requirement on 18 November 2025 for newly notified PSCs and has a twelve-month transition window closing around November 2026 for existing PSCs in office before that date.
The two routes available to you are the GOV.UK One Login self-service identity-verification service (free at point of use) and the Authorised Corporate Service Provider (ACSP) route, where an AML-supervised UK firm (typically your accountant or company-secretarial agent) verifies your identity on your behalf for a fee. Whichever route you use, the outcome is the same: a verified natural-person identity record at Companies House plus a unique permanent personal code under ECCTA s.68 that you then quote on every Companies House filing that records you as a PSC.
The good news for the data-protection-conscious reader is that the publication restriction in ECCTA section 69 protects your residential address (where it differs from your service address), the full day of your date of birth, your identifying-document number, and your biometric data from public-register visibility. Only your full legal name, the month and year of your birth, your nationality, your country of residence, your service address, the nature of your control, the date you became a PSC, and your verified-status flag appear in the publicly searchable PSC record.
For the upstream definitional explainer covering directors and PSCs together, see our complete guide to identity verification in the UK. For the submission-mechanic screen-by-screen walkthrough, see our identity verification form page. For the US-resident dimension, see our US-based directors page. Here are the questions PSCs ask most often.
What Is a "Person With Significant Control" and How Do I Know If I Am One?
A natural person who meets any one of the five PSC tests under Companies Act 2006 Schedule 1A. The tests are the operational anchor for the entire PSC regime, and they are worth setting out alongside a property-and-FIC-grounded example for each.
| PSC test (CA 2006 Sch 1A Condition) | What it captures | FIC or property-SPV example |
|---|---|---|
| Condition 1: more than 25 percent of shares | The simplest test, pure shareholding percentage by number of shares | Adult-child holding 30 percent of growth-class shares in a Family Investment Company crosses Condition 1 |
| Condition 2: more than 25 percent of voting rights | Voting-right percentage (may differ from share count where share classes carry weighted votes or non-voting classes) | Founder-parent holding 100 percent of voting-class shares and 0 percent of growth-class shares is PSC under Condition 2, not Condition 1 |
| Condition 3: right to appoint or remove a majority of directors | Director-appointment right (typically in the company's articles or a shareholders' agreement) | Family trust whose articles allow the trustees to appoint and remove a majority of the FIC board satisfies Condition 3 |
| Condition 4: significant influence or control | Fact-specific test capturing arrangements outside the formal shareholding, voting, and appointment tests | Family-office principal who by deed has reserved-power to direct material company decisions; formal shareholding may be below 25 percent but Condition 4 still bites |
| Condition 5: significant influence or control over a trust or firm that itself meets Conditions 1 to 4 | The look-through condition, capturing beneficiaries and trust-controllers who exercise control over an upstream entity that is itself a PSC | Beneficiary with reserved power under the trust deed to direct the trustees of a discretionary trust that holds 30 percent of the FIC shares can be Condition 5 PSC of the FIC even though the trust is the immediate shareholder |
Most natural-person PSCs cross the line via Condition 1 (25 percent shareholding) or Condition 2 (25 percent voting rights). Conditions 4 and 5 (the "significant influence or control" tests) are more nuanced and typically rely on the natural person's role in the trust or firm's decision-making.
If your accountant or company-secretarial agent has told you that you are a PSC, you are. The PSC analysis was done at the point of incorporation or share-issue and was filed at Companies House via the PSC01 first-notification form (or PSC02 to PSC04 if your status changed). If you have not been told, you almost certainly are not, but in FIC and family-trust contexts the analysis is fact-specific and worth confirming.
Do I Have to Verify Identity If I Am a PSC But Not a Director?
Yes. ECCTA 2023 s.64 ("Identity verification of persons with significant control") applies the verification requirement to natural-person PSCs as well as to natural-person directors. The two cohorts are treated equivalently. You verify once as a natural person and receive one personal code that covers your PSC interest regardless of whether you are also a director.
This catches a wider PSC population than directors. Adult-child shareholders of Family Investment Companies, spouses who hold 25 percent or more in a property SPV without being on the board, joint-venture partners holding 25 percent or more in a UK property development SPV, beneficiaries of discretionary trusts where the look-through bites, passive co-investors gifted shares post-incorporation, angel investors whose shareholding crossed the 25 percent line on a fundraise. All in scope under s.64.
I Am a PSC of Multiple UK Companies. Do I Verify Multiple Times?
No. One natural-person verification produces one personal code that covers every UK directorship and every UK PSC interest you will ever hold. The statutory anchor is ECCTA s.68 (allocation of unique identifiers). The code is permanent and persists across all your UK roles.
The per-company step is providing the code on each company's next confirmation statement (CS01) or appointment or PSC change filing. That is filing-side admin, not re-verification. A PSC of five UK companies verifies once and then has the personal code recorded on each of the five companies' next confirmation statements. For the CS01 integration, see our confirmation statement changes page.
I Am a Beneficiary of a Discretionary Family Trust That Owns 25 Percent or More of a UK Company. Am I the PSC or Are the Trustees?
This is the operationally trickiest PSC question because the analysis turns on the look-through mechanics at CA 2006 Sch 1A Conditions 4 and 5, and the answer is fact-specific.
Starting point: in most discretionary trust structures, the trustees are the PSCs because they hold legal title to the shares, exercise the voting rights, and make discretionary decisions on income and capital distributions. The trustees verify identity per the PSC regime. Each trustee is a separate natural person and verifies individually.
But the look-through mechanics can flip the analysis to a beneficiary in specific circumstances:
- The beneficiary is also a trustee (a "beneficiary-trustee" who wears both hats).
- The beneficiary has a fixed entitlement to income or capital that meets one of Conditions 1 to 3 (so the beneficiary is not just an object of discretionary trust powers but holds defined rights crossing the 25 percent threshold by share, voting, or appointment-right equivalents).
- The beneficiary has a reserved power under the trust deed to direct trustee decisions or to compel trustees to vote in a particular direction on company resolutions.
- The beneficiary, as a matter of substance over form, exercises significant influence over how the trustees act (Conditions 4 and 5).
Consider Mr Patel, a UK-resident beneficiary of a discretionary family trust established by his late father in 2018. The trustees (Patel's mother, his uncle, and a professional trust corporation) hold 60 percent of a UK property-SPV company through the trust. Under the trust deed Patel has no reserved power, no fixed entitlement, and does not act as a trustee. He is not a PSC under any of Conditions 1 to 5. The three trustees are the PSCs, and each verifies individually. By contrast, if the deed had given Patel a fixed life interest in 50 percent of trust income plus a reserved power to compel trustees to vote in a particular direction on FIC resolutions, Condition 5 would bite and Patel would need to verify alongside the trustees.
Each trust and FIC structure must be analysed separately. We do not advise on trust structuring; the trust deed and the underlying governance is the operative document. Cross-link to our FIC pillar page and the underlying trust pillar pages for the wider framework.
I Have Growth Shares in a Family Investment Company. Am I a PSC?
Depends on the substance of the growth-share rights, not the label. The standard PSC analysis under CA 2006 Sch 1A applies. Growth shares typically carry limited voting rights (often non-voting or fractionally voting), future economic rights only (entitlement to value above a hurdle, with no entitlement to existing value), and are issued in volumes that may or may not exceed 25 percent of the company's total share count.
Consider the Okonkwo Family Investment Company. Share structure: 100 founder shares (full voting plus full dividend access) held by Mr and Mrs Okonkwo on a 50/50 basis; 400 growth shares (voting at one-tenth the founder rate, value-above-hurdle only) held by their four adult children at 100 shares each; 50 dividend-access shares (non-voting, dividend-only) held by Mrs Okonkwo for income-smoothing.
- Mr and Mrs Okonkwo each hold 50 founder shares of 100 (50 percent of the founder class but more importantly the dominant voting bloc by weighted vote). Each is a PSC under Condition 1 (founder-class shareholding) and Condition 2 (voting rights weighted to the founder class).
- Each adult child holds 100 growth shares of 400 (25 percent of the growth class, but only 100 of 550 total shares, or 18.2 percent by aggregate share count). Below 25 percent by aggregate. Voting rights weighted at one-tenth, so much smaller by voting weight. On a substance-of-rights analysis, each adult child is not a PSC.
- The analysis would turn differently if the growth class were treated as a separate class for PSC threshold purposes or if the four siblings held joint voting rights or a shareholders'-agreement-style reserved power. Each fact-pattern must be analysed against CA 2006 Sch 1A interpretation.
Practical reality: the FIC's company secretary or accountant did the PSC analysis at incorporation and on each share-issue. If they have notified you that you are a PSC, you are. If they have not, you are likely not. We do not advise on FIC share-class structuring; see our FIC disadvantages page for the wider FIC governance framing.
My Spouse and I Jointly Own 30 Percent of a UK Company. Are We Both PSCs?
Yes. Joint holders of shares are each treated as holding the full percentage for PSC threshold purposes per CA 2006 Sch 1A interpretation. A 30 percent joint shareholding crosses the 25 percent threshold for each joint holder. Both spouses verify identity individually and each receives their own permanent personal code under ECCTA s.68.
Mr and Mrs Nakamura are a UK-resident married couple jointly owning 35 percent of a UK BTL property SPV. The remaining 65 percent is held by an unrelated joint-venture partner. Both Nakamuras are PSCs under Condition 1. Two verifications, two personal codes, two PSC entries on the SPV's public PSC record. The company secretary or accountant quotes both codes on the SPV's next CS01 confirmation statement.
The same applies to civil partners. Co-investors who are not spouses or civil partners but who hold shares jointly (for example, two unrelated business partners holding a single share certificate jointly) are typically each treated as PSCs in the same way.
What Does the Public Register Show About Me and What Does It Not Show?
The publication restriction at ECCTA s.69 ("Identity verification: material unavailable for public inspection") plus the Companies House published display rules produce the following visibility matrix for a verified PSC.
| Field | Public on PSC record | Authority |
|---|---|---|
| Full legal name | YES | CA 2006 plus Companies House public-register architecture |
| Any former names (deed poll, marriage) where notified | YES | CA 2006 plus Companies House published display rules |
| Month and year of birth (for example "June 1975") | YES | Companies House published display rules |
| Full date of birth day (for example "12 June 1975") | NO (day suppressed) | ECCTA s.69 plus Companies House published display rules |
| Nationality | YES | CA 2006 plus Companies House published display rules |
| Country of residence | YES | Companies House published display rules |
| Service address (registered office or separately designated service address) | YES | CA 2006 plus Companies House public-register architecture |
| Residential address (where different from service address) | NO | ECCTA s.69 plus CA 2006 ss.243 to 244 protected-information regime |
| Date became a PSC | YES | CA 2006 PSC architecture |
| Nature of control (which PSC test you meet) | YES | CA 2006 PSC architecture |
| Verified-status flag (yes or no) | YES | Companies House published display rules |
| Identifying document type and number | NO | ECCTA s.69 publication restriction |
| Biometric photograph | NO | ECCTA s.69 plus Data Protection Act 2018 |
| Personal code (as a literal string) | NO | ECCTA s.68 (code is the identifier; verified-status flag is public) |
| Route used (One Login or ACSP) | NO | Internal verification audit only |
This is the operational protection that allows you to comply without exposing identity-theft-attractive data on the public register. For PSC readers with particular safety concerns (a domestic-violence survivor, a journalist, an activist, or otherwise at risk), Companies House operates a stronger protected-information regime via application, with additional residential-address protections available under CA 2006 ss.243 to 244 plus ss.790ZF to 790ZG.
What If I Do Not Want My Residential Address on a Public Register at All?
You do not have to put it on one. Your residential address is not on the public register and has not been since the Small Business Enterprise and Employment Act 2015 removed residential addresses from the public PSC and director registers.
You provide a service address (typically the registered office of the company you are a PSC of, or a separately designated service address such as a chartered accountant's office, a service-address provider, or your solicitor's office), and the service address is what is publicly visible. The residential address is privately recorded by Companies House for statutory-correspondence purposes but not published.
If you have particular safety concerns, the protected-information regime under CA 2006 ss.243 to 244 plus ss.790ZF to 790ZG provides stronger protection. Apply via the Companies House published protected-information procedure. Typical applicants include domestic-violence survivors, journalists, public-facing professionals at risk of harm, and individuals subject to a credible threat.
What Happens to My Personal Code If My Circumstances Change?
The personal code itself is permanent. It does not change when your name changes, when you move house, when you marry or divorce. The statutory anchor is ECCTA s.68: one natural person, one unique identifier, retained across all your UK roles and across changes in personal circumstances.
The underlying data recorded by Companies House is updated separately. A name change is notified via the standard change-of-particulars filing (PSC04 and related) for each company you are a PSC of. An address change is notified the same way. If you change your legal name (deed poll, marriage, civil partnership, transgender transition), the verification record at Companies House should be updated to surface the former name and new name so historical Companies House records cross-link correctly. The code itself stays the same.
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What Are the Consequences If I Do Not Verify?
Three-layer consequence stack.
- Blocked Companies House filings. The company you are a PSC of cannot complete its next confirmation statement filing without your personal code recorded against your PSC entry. The company falls into default on its CA 2006 s.853A duty and accrues a civil penalty under Sch 1B CA 2006 (up to £5,000 per failure).
- Criminal offence for continuing to act as a PSC unverified. Once the transition window closes (around November 2026 for existing PSCs, immediately for new PSC notifications from 18 November 2025), continuing to hold the PSC status without a personal code is an offence under the ECCTA-inserted Companies Act 2006 provisions covering identity verification.
- Practical consequences for the company you are a PSC of. Confirmation-statement defaults, striking-off exposure under CA 2006 ss.1000 to 1011, and reputational damage on the public register. For a PSC of a Family Investment Company or a property SPV, this affects the company plus your fellow PSCs plus the family or joint-venture structure as a whole.
The strong practical recommendation is to verify within the transition window and not let the deadline drift. The verification step is operationally light (5 to 15 minutes via One Login or 1 to 5 business days via ACSP). The cost of missing it is the company's filing position plus your personal offence exposure.
Does Verification Scope Shift When a Family Investment Company Issues New Share Classes?
It can. The scope-shifting question is whether the new share-class issue takes any natural person across the 25 percent PSC threshold or removes them from it. Common FIC patterns:
- Gift of growth shares to adult children at FIC inception. The adult children become PSCs at the point their growth-share holding crosses 25 percent by an applicable PSC test.
- Subsequent share-issue to a new family member. That family member becomes a PSC if their issue takes them above 25 percent.
- Share-class reorganisation (for example, reclassifying growth shares as dividend-access shares for IHT-side restructuring purposes per FA 1986 s.102B). May shift PSC status across classes.
Each share-issue or reorganisation requires fresh PSC analysis plus PSC02, PSC03, or PSC04 filings. If you become a new PSC after 18 November 2025 (for example, you are issued growth shares for the first time that cross the 25 percent threshold), you must verify identity before the PSC notification can be filed. If you cease to be a PSC (for example, your shares are bought back or reclassified out of scope), your existing verification status persists but you no longer appear as a PSC of that company on the public register.
What About Corporate PSCs and the Later Phase?
Natural-person PSCs verify now. Corporate-PSC officer verification comes into scope at a later phase scheduled no earlier than November 2026 per the Companies House campaign page.
If your UK SPV has both natural-person PSCs (founder-parents, adult-child growth-shareholders) and a corporate PSC (a Jersey holding company, a Delaware LLC, an English Limited Partnership, a corporate trustee), the natural-person PSCs verify now under the 18 November 2025 plus twelve-month transition regime. The corporate-PSC officer verification is later-phase. Do not conflate the two scopes.
For complex multi-tier structures (a UK SPV with a corporate PSC at one tier plus natural-person ultimate-beneficial-owners further up), the natural-person verification for the ultimate-beneficial-owners may already be triggered via the Condition 4 or 5 look-through if those natural persons are PSCs through the look-through chain. Verify the structure with your accountant.
Is Identity Verification the Same as Register of Overseas Entities Verification?
No. Different registers, different verification regimes. ECCTA PSC verification covers UK COMPANY PSCs, which is what this page covers. The Register of Overseas Entities (RoE) covers OVERSEAS-ENTITY BENEFICIAL OWNERS who own UK property through a non-UK legal entity (BVI, Jersey, Guernsey, Cayman, Delaware LLC, and similar) under ECTEA 2022.
If you are a beneficial owner of an overseas entity that owns UK property, the RoE verification regime applies to you through the overseas-entity's annual update statement, with separate UK-regulated agent verification and a separate annual update obligation. For the consequence stack on RoE non-compliance, see our RoE non-compliance consequences page. For the broader RoE annual update mechanic, see our RoE annual update statement page.
If you are also a PSC of a UK company (because the UK company is part of a different structure), the ECCTA PSC verification applies separately. Each regime has its own verification mechanic and its own consequence stack.
I Am a US-Resident PSC. Does That Change Anything?
Same regime applies. US-resident PSCs of UK companies must verify identity per ECCTA s.64 regardless of country of residence. The practical mechanic typically favours the ACSP route over GOV.UK One Login, because One Login is optimised for UK-resident users with UK-issued identity documents (UK passport, UK driving licence, UK address). ACSPs operating under MLR 2017 are fluent in US identity documents (US passport, US state driver's license, US Social Security card, US utility bills, US bank statements).
For the full US-resident operational walkthrough including the ACSP route, US identity-document acceptance, time-zone-aware video-verification scheduling, and the four-way US/UK disclosure overlap (FATCA, Form 5471, FBAR, and ECCTA), see our US-based directors page. The US-resident-PSC coverage is the secondary thread on that page; the regime is the same as for US-resident directors.
What Does the Verification Actually Involve Operationally?
There is no numbered Companies House paper or PDF form. Verification is delivered electronically through one of two routes:
- GOV.UK One Login. Free self-service web and mobile flow at signin.account.gov.uk. Interactive document scan, biometric face-match, security questions. Typically 5 to 15 minutes if you already have an active One Login account from prior tax-side filings; under 30 minutes from a cold start.
- ACSP route. Your accountant or company-secretarial agent verifies your identity using its KYC platform under MLR 2017 supervision. Typically £50 to £300 one-off; 1 to 5 business days from engagement to code-in-hand.
For the screen-by-screen depth on what the verification flow looks like, what data Companies House captures, and how the resulting personal code flows into the CS01, AP01, PSC01, and IN01 filings, see our identity verification form page.
What Is My Next Step?
Five-step operational sequence:
- Confirm your PSC status. Speak to the company secretary or accountant of every UK company you are a PSC of and confirm they have your current PSC notification status on file.
- Choose your route. GOV.UK One Login is free, self-service, and fast for tech-comfortable readers with an active One Login account plus a UK passport. The ACSP route is typically £50 to £300, accountant-mediated, and useful for less-tech-comfortable readers, non-UK-residents, multi-trust complexity, and FIC participant-shareholders who want a bundled family engagement.
- Gather documents. Passport (UK or non-UK in date), driving licence, BRP, BRC, or Frontier Worker permit. Address-of-residence anchor (utility bill, bank statement) for the ACSP route.
- Complete verification. One Login takes 5 to 15 minutes typical. ACSP engagement takes 1 to 5 business days typical.
- Record the personal code. Store the code in your password manager or safe. Provide it to the company secretary or accountant of every UK company you are a PSC of, who will quote it on the next CS01 confirmation statement filing for each. If you also hold UK directorships, the same personal code covers those.
For the upstream definitional explainer, see our complete guide to identity verification in the UK. For the form-mechanic submission walkthrough, see our identity verification form page. For the multi-SPV portfolio operational design, see our ECCTA identity verification for landlord LtdCos page. For the scam-vetting question on Companies House emails about verification, see our Companies House emails page. For the FIC pillar context, see our FIC pillar page and the FIC disadvantages page.