It is now a requirement for all UK private companies, including companies limited by guarantee and UK LLPs, to keep a Person of Significant Control (PSC) Register.

This has been introduced by the Small Business, Enterprise and Employment Act 2015 to increase corporate transparency by creating a full picture of the ownership of businesses.

Co-operative and community benefit society RSL

Most registered social landlords (RSLs) are societies registered under the Co-operative and Community Benefit Societies Act 2014 (formerly the Industrial and Provident Societies Act 1965). The new rules requiring a PSC register DO NOT apply to registered societies, therefore such a society does not need a PSC register.

However, the new regulations DO apply to companies that are subsidiaries of (or otherwise linked to) RSLs. Accordingly such a company must have a PSC register. However if the RSL parent is a body registered under the 2014 Act, it does not count as a person with significant control for the purposes of the new regulations, even if it owns all the shares.

Please note however that the company still needs to have a PSC register, which cannot just be left blank. In these circumstances, the register should contain a statement to the effect that there is no person with significant control.

Company RSL

If the RSL is incorporated as a company rather than a registered society, it must have a PSC register and would require to be referred to as a PSC in the register of any wholly owned subsidiary.