What are ‘Persons with Significant Control’ (PSCs)?

A Person with Significant Control, usually referred to as a PSC, is an individual who ultimately owns or controls a UK company.

The term comes from the Companies Act 2006, which introduced the PSC rules in 2016 to improve transparency over who really sits behind UK corporate entities.

For regulated professionals, PSCs matter for two reasons. First, companies are legally required to identify and record them. Second, the concept overlaps directly with the definition of “beneficial owner” under the UK’s Money Laundering Regulations 2017 (as amended) (MLRs).

Understanding how the two fit together is central to applying a proportionate, defensible AML approach.

Where the PSC rules come from

The PSC rules were introduced through amendments to the Companies Act 2006. They require most UK companies and LLPs to:

• identify individuals who have significant control over them;
• maintain their own internal PSC register;
• file that information at Companies House.

Companies must take reasonable steps to identify all PSCs. That usually means reviewing shareholdings, voting rights, board appointment rights and any agreements that give someone influence or control. 

The PSC information filed at Companies House forms part of the public register, which means it is accessible to regulators, counterparties and AML-regulated firms.

Companies House reforms and PSC transparency

Recent reforms have strengthened the role of Companies House, including mandatory identity verification for directors and PSCs.

The aim is to improve the reliability of information on the public register and reduce misuse of UK corporate entities.

For AML purposes, verified PSC information improves confidence in the data. It does not remove your obligation to assess ownership and control in context.

A verified PSC is confirmed as a real individual. Your responsibility is still to understand whether the declared structure reflects the actual economic reality.

How the law defines a PSC

Under the Companies Act 2006, an individual is a PSC if they meet one or more of the following conditions:

• they hold more than 25% of the shares in the company;
• they hold more than 25% of the voting rights;
• they have the right to appoint or remove a majority of the board;
• they otherwise have the right to exercise, or actually exercise, significant influence or control;
• they exercise significant influence or control over a trust or firm that itself meets one of the above conditions.

The 25% threshold mirrors international transparency standards and aligns closely with AML definitions of beneficial ownership.

The definition also recognises that control is not always about shareholding. Influence can arise through agreements, veto rights or other governance arrangements.

PSCs and beneficial owners under AML law

Under the MLRs, you must identify a company’s beneficial owners. Regulation 5 states that a beneficial owner is someone who:

• owns more than 25% of the shares, directly or indirectly;
• controls more than 25% of the voting rights;
• or otherwise exercises control over the company.

If that sounds familiar, it should. The PSC rules under the Companies Act use the same 25% threshold and the same idea of ownership and control.

In most straightforward cases, the people listed as PSCs will also be the company’s beneficial owners for AML purposes.

The difference sits in what the rules are trying to achieve.

The PSC register is a company law requirement. It’s about public transparency. Companies must identify their PSCs and file that information at Companies House.

Beneficial ownership under the MLRs is your responsibility as a regulated professional. It forms part of your customer due diligence. You must identify and take reasonable steps to verify who ultimately owns or controls the company.

So while the two concepts overlap heavily, they are not interchangeable. PSC information is a helpful starting point but your AML duties don’t end with checking the Companies House entry.

Why PSCs matter in AML work

When onboarding a corporate client, you are required under Regulation 28 of the Money Laundering Regulations to:

• identify the beneficial owners;
• take reasonable measures to verify their identity;
• understand the ownership and control structure.

The PSC register is a useful starting point. It provides a declared view of who the company says controls it.

However, sector guidance is consistent on this point: Companies House information is a source, not the conclusion.

If you are supervised as an accountant, AMLGAS expects you to look beyond formal filings where necessary to understand who ultimately owns or controls the entity.

If you operate in the legal sector, LSAG guidance makes clear that identifying beneficial owners requires an understanding of both legal and actual control, particularly where complex or layered structures are involved.

Property businesses and high-value dealers supervised by HMRC are also expected to identify and verify ultimate beneficial owners, not just rely on company filings.

Final thoughts

Persons with Significant Control are defined in the Companies Act 2006 as individuals who ultimately own or control a UK company.

The PSC rules improve corporate transparency. The AML framework builds on that transparency by requiring regulated professionals to identify and verify those individuals as beneficial owners.

In practice, PSC information is one part of the ownership picture. Your role is to connect the public record, the structure presented by the client and the underlying reality of who exercises control.

When you can clearly explain who holds significant control and how you verified that conclusion, your approach is aligned with both company law and AML expectations.