The Ultimate Guide to the PSC Register & UBO Compliance in 2026
There are a lot of misconceptions about the UK’s Persons of Significant Control (PSC) register. The main one is that people wrongly conflate a “PSC” with a “UBO”.
They are not the same thing, and getting this wrong is a breach of MLR 2017.
Here's what the register tells you.
What Is a PSC?
A Person of Significant Control (PSC) is a human or UK-registered legal entity who:
Owns or controls more than 25% of a company's shares or voting rights.
Appoints or dismisses the directors.
Holds any other significant influence over the company.
The register is public. It is not reliable. And it is not a UBO register.
PSC vs. UBO: Not the Same Thing
Stephen Abbot-Pugh, financial crime journalist and former Head of Technology at Open Ownership, said, “It’s fully acceptable in the UK not to go back to the ultimate beneficial owner.”
Here’s why.
A PSC is not always the ultimate beneficial owner (UBO). The distinction matters because your AML obligations require you to find the UBO, not merely the PSC.
EU law requires companies to report the owner at the top of the chain.
UK law requires companies to report only the direct owner, even if that person is not the UBO.
In practice: A company lists its PSC on Companies House but discloses its UBO to you – the obliged entity – and you must verify it yourself.
As JMLSG guidance states, “Information on the PSC register may thus differ from other beneficial ownership information and not necessarily be inaccurate.”
Why You Cannot Rely on the PSC Register for UBO Verification
The Money Laundering Regulations 2017 are unambiguous:
"Relevant persons do not satisfy their requirements under paragraph (4) by relying only on the information contained in the register of people with significant control." — MLR 2017, 28.9
Five specific weaknesses explain why.
1. The "Next Level" Loophole
If Company A is owned by Company B – a UK-incorporated entity (also called a Relevant Legal Entity) – Company A needs only list Company B. It need not look further up the chain to Company C, Company D, or whoever sits at the top. The Companies Act 2006 permits this.
2. Poor Data Quality
Open Ownership's 2025 report found that nearly half of all PSC data is potentially unreliable:
20% of entries name no individual beneficial owner, pointing to non-compliance, gaps in reporting, or deliberate concealment.
20% list multiple beneficial owners, with some entries showing combined shareholdings that exceed 100%.
3. Vague Ownership Bands
The register does not say "this person owns 76% of the company." It says "75% or more."
Because the register uses bands (e.g., 75% or more), it fails to identify 'Aggregation of Interests', where multiple parties acting in concert each hold 24%, falling just below the reporting threshold but maintaining 100% collective control.
This is obviously imprecise and requires compliance teams to manually dig into the shareholder disclosures to identify, then verify, the exact percentages.
4. The Trust Backdoor
When a trust owns or controls a UK company, the register shows only the trustees. Settlors and beneficiaries do not appear. Legal control is visible; economic benefit is not.
5. Use of Nominees
Open Ownership’s 2025 report found that some individuals appear as beneficial owners of hundreds or thousands of entities, a pattern consistent with shell companies and nominees.
6. Single Source Limitation
Trusting a single source leaves room for error or deception; checking several sources exposes inconsistencies and brings the true beneficial owner into the open. As the Financial Action Task Force (FATF) advises, compliance teams should take a multi-pronged approach to UBO verification, using “several sources of information”.
Case Study: Lemixton Solutions Ltd
Finance Uncovered's investigation into Lemixton Solutions made the PSC register's weaknesses concrete.
The register showed a single owner: a 71-year-old woman named Wendy Conroy. Behind that entry, the company was processing millions of dollars in Uzbek state contracts. Conroy was a nominee director, acting on instructions from a corporate services provider to whom she had signed off power of attorney. The company later filed a backdated statement confirming ownership via a trust, meaning the real beneficiaries never appeared on the register at all.
What this tells compliance teams:
A natural person on the PSC register is not proof of genuine control.
Trust arrangements can hide economic benefit entirely from public view.
Backdated filings are a known tactic. The register reflects what was filed, not necessarily what was true.
What the ECCTA 2023 Changed
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) attempted to turn Companies House from a filing cabinet into a regulator, and, in so doing, increase the reliability of PSC data.
Mandatory identity verification for all new and existing directors, PSCs, and officers. A "verified" marker on the register will improve data quality – but it does not replace your own CDD obligations
Stronger registrar powers. The registrar can now reject filings, strike material from the register, and share data with law enforcement. Since March 2024, over 106,000 addresses have been removed where personal data was used without consent
No more internal registers. As of November 2025, the Companies House central register is the only legal record.
One problem remains: a verified PSC is still not necessarily the UBO.
What Happens If You Don’t Know the Difference
Under UK anti-money laundering (AML) legislation, compliance teams must verify the beneficial owner of a legal entity.
Banks must “look through” the RLE to find the actual human being at the top.
Under the Money Laundering Regulations 2017 (Regulation 30A), banks have a legal duty to report a "material discrepancy" to Companies House if the UBO differs from the PSC.
Under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), which came into full force on September 1, 2025, a bank can be held criminally liable if it lacks "reasonable procedures" to prevent fraud committed for its benefit.
The key point: Companies publicly report their PSC, but disclose their UBO to obliged entities, which in turn verify that against “independent and reliable” sources.
What Are “Independent and Reliable” Sources?
The FATF and British AML legislation frequently states that UBO verification – and customer due diligence generally – must use “independent and reliable” sources. What does that mean?
Company registries.
UBO registries.
Other government databases, such as land and property registries.
How to Find the Real UBO
Three routes exist, each with serious limitations.
1. The Trust Registration Service (TRS)
HMRC runs the TRS, which holds information on trusts. But accessing it is difficult. Stephen said, “Journalists and investigators can access it, but it’s notoriously difficult.”
Access is restricted to those with a "legitimate interest," including obliged entities, but the process is slow and circular:
Requesters must explain in writing why they suspect a specific trust is involved in money laundering.
This often means proving what you are trying to find out.
Expect an eight-week wait, frequently with no useful result.
"The FATF is pretty clear on this, in Recommendation 25,” said Stephen. “Trust UBOs should be up-to-date, accurate, and accessible. But that isn’t the case now.”
2. The Register of Overseas Entities (ROE)
The ROE records the beneficial owners of UK property held by overseas entities, over 32,000 registered as of March 2025. Its limits:
Covers only property bought in England and Wales since January 1999, Scotland since December 2014, and Northern Ireland since September 2022.
Where no beneficial owner can be identified, managing officers are listed instead.
LSE and Transparency International research found that 10% of overseas entities have reported no beneficial owners, and 34% list at least one corporate beneficial owner, which restarts the disclosure chain.
3. Manual Shareholder Mapping
Compliance teams often verify UBOs by manually unwrapping corporate structures layer by layer using shareholder data. The weaknesses are well known:
Nominee shareholders can be placed in front of real ones.
A single register is never enough. Cross-referencing across multiple international registries is the only way to build a reliable picture of complex structures.
The 2026 Horizon: Overseas Territories
The PSC problem does not stop at Dover. Most UK Overseas Territories (OTs) and Crown Dependencies are committed to implementing beneficial ownership registers by July 2026. But the picture is uneven. Here’s where things stand:
Public registers already live: Gibraltar, Montserrat, and St Helena. The Falkland Islands has committed to public access by July 2026.
Legitimate interest models: BVI, Bermuda, Cayman Islands, Jersey, Guernsey, and the Isle of Man. You must demonstrate a reason to access them. They are better than nothing. They are not public registers.
The British Virgin Islands: Still Waiting
The BVI missed its original 2023 deadline. Its revised go-live is April 2026.
Even then, access will be restricted, and trust structures controlling BVI companies will not be disclosed. The trust loophole survives offshore. Two problems that the 2026 commitments do not fix:
Tip-off risk. In some legitimate interest models, beneficial owners are notified when their information is accessed. That notification can trigger asset movement before an investigation concludes.
The trust gap. OT registers are not required to disclose the settlors or beneficiaries of trusts that control companies. Legal ownership may be visible. Economic benefit will not be.
The practical position for compliance teams today: if a UK company's PSC is a BVI or Jersey entity, you cannot verify the chain from a public register. You are dependent on the subject's own disclosure and manual research across multiple international registries, with all the limitations.
The 2026 commitments are progress. They do not solve the UBO problem.
Identifying Ultimate Beneficial Owners (UBO) Across Borders
The PSC register is a starting point.
It tells you who reported control. It does not tell you who holds it. Nominees, trusts, and layered corporate structures mean the real UBO is often invisible to anyone who stops at Companies House.
The only way through is cross-border verification using live, official sources, following the ownership chain across every jurisdiction it passes through, in real time.
That is what Kyckr does. By extracting live shareholder data directly from official company registries worldwide, Kyckr maps complex structures and surfaces the true UBO, cutting through nominees and shell layers that a single-country search will never reach.
One register is never enough. Kyckr gives you all of them.
Frequently Asked Questions
What is a PSC?
A Person of Significant Control is any person or UK-registered legal entity that directly or indirectly owns or controls a UK company, through shares, voting rights, the power to appoint directors, or significant influence. A PSC can be a company, not only a human being. When it is, the register stops there. It does not show who controls that company.
What is the difference between a PSC and a UBO?
A PSC is whoever reports control to Companies House. A UBO is the human being who ultimately owns or benefits from the company. UK law requires only the direct owner to be reported. Your AML obligations require you to find the UBO. Those are not always the same person.
What is a Relevant Legal Entity?
A UK-registered company that meets the PSC thresholds. When one appears on the register, you must look through it to find the human being behind it. The register does not do this for you.
Can I rely on the PSC register to verify beneficial ownership?
No. MLR 2017 is explicit: the PSC register alone does not satisfy your UBO verification obligations. The FATF agrees. You need several sources: company registries, UBO registries, and government databases such as land and property registers. Nominees, trusts, and layered structures mean the real UBO is often invisible to anyone who stops at Companies House. One register is never enough.