Establish whether ownership, voting rights or other control conditions make an individual a PSC before selecting the appropriate identity-verification and Companies House route.

Determine the Appropriate PSC Ownership and Control Route.

Whether the position involves shares, voting rights, appointment or removal rights, an LLP interest, indirect ownership, a trust, an agreement or significant influence or control, our professional team helps you identify the entity, relevant rights and apparent registrable subject before separating PSC classification from the individual's identity-verification process.

Identify the relevant company, Company Limited by Guarantee, LLP or other entity before applying the appropriate PSC framework to its ownership and control position.

Review the actual ownership, voting and control rights rather than relying only on a person's title as director, shareholder, member, trustee or beneficial owner.

Assess whether the relevant position concerns shares, voting rights, appointment or removal rights, LLP surplus-asset rights or another significant influence or control condition.

Consider direct and indirect ownership or control, including legal-entity chains, agreements, trust arrangements and other structures that may affect who is actually registrable.

Identify the appropriate registrable subject, distinguishing an individual PSC from a relevant legal entity or another permitted registrable entity before an individual verification route is selected.

Separate PSC classification from identity verification, recognising that an identity check establishes who the person is but does not itself establish ownership, control or PSC status.

Establish the evidence relevant to the ownership or control position, including Articles, LLP agreements, ownership charts, shareholder or voting agreements, trust information and relevant records.

Distinguish current individual PSC verification from separate entity notification, formation, filing or governance work so that completing one stage is not incorrectly treated as completing another.

Identify when an unclear ownership chain, disputed right, trust, agreement, significant-influence question or possible historic error requires separate professional or legal analysis rather than an automatic verification purchase.

Reduce avoidable administrative errors and back-and-forth by establishing the entity, relevant rights, apparent registrable subject and appropriate next route before identity verification or PSC notification is progressed.

Determine the Appropriate PSC Route

Coddan CPM is a UK-based legal and corporate services firm providing professional support to identify the apparent PSC, ownership or control position before the relevant identity-verification or Companies House process is selected.
Call us on: 033 0808 0089 to discuss the appropriate PSC ownership, control and verification route for your circumstances.

Understanding PSC Rules: Shares, Voting Rights & Significant Influence Verification

Identify the person before choosing the verification route

Who Must Verify as a PSC? Ownership, Voting Rights and Significant Influence or Control

A shareholder, guarantor, company director, LLP member, trustee or beneficial owner is not automatically an individual person with significant control. The first task is to establish who is actually registrable as a PSC and whether the entry should instead concern a relevant legal entity or another registrable legal entity.

Coddan can review the entity, the rights and the available ownership or control information, identify the apparent verification subject and separate identity verification from the company’s or LLP’s PSC analysis and notification work.

The practical question is not simply who owns something

Before an individual verifies as a PSC, the relevant company or LLP must establish whether that person meets a statutory ownership or control condition. The answer can depend on shares, voting rights, rights to appoint or remove decision-makers, rights over surplus assets in an LLP, indirect holdings, agreements or other significant influence or control.

The identity check answers who the person is. It does not answer whether the person has the relevant ownership or control. Those questions must not be collapsed into one another.

Identify the entity

Confirm whether the question concerns a company, CLG, LLP or another entity to which its own PSC rules apply.

Identify the rights

Review the actual ownership, voting, appointment, surplus-asset or other control rights—not only the person’s job title.

Identify the registrable subject

Establish whether the register should identify an individual PSC, an RLE or another permitted registrable legal entity.

Then address verification

A living individual PSC must complete the current identity-verification and PSC Personal Code steps. A legal entity does not receive an individual Personal Code.

Which ownership or control condition applies?

An individual can be a PSC by meeting one or more conditions. The detailed legal test depends on the entity. The descriptions below are an orientation, not a substitute for reviewing the constitution, LLP agreement, ownership chain and other relevant evidence.

Condition 1

Ownership or entitlement

For a company, this commonly concerns holding more than 25% of its shares. For an LLP, the corresponding question concerns rights to more than 25% of the surplus assets on a winding up. The entity-specific test and any indirect holding rules must be applied.

Condition 2

Voting rights

The person may be a PSC where they hold, directly or indirectly, more than 25% of the relevant voting rights. Voting arrangements and rights exercised through another legal entity may require separate examination.

Condition 3

Appointment or removal rights

For a company, this concerns the right to appoint or remove a majority of the board. For an LLP, the equivalent test concerns the right to appoint or remove a majority of those entitled to take part in management.

Condition 4

Other significant influence or control

A person may have the right to exercise, or actually exercise, significant influence or control by another route. This condition is fact-sensitive and must be considered using the current statutory guidance.

Condition 5

Control through a trust or firm

In limited circumstances, an individual can be registrable because they exercise significant influence or control over a trust or firm without legal personality which itself meets another control condition. The trust or firm does not receive an individual Personal Code.

Important boundary

Meeting one condition can be enough

The customer should not try to select a convenient condition or assume that only share ownership counts. All relevant conditions and all applicable natures of control must be considered.

Company and LLP tests are related, but they are not interchangeable

The same person-centred verification framework can apply across companies and LLPs, but the underlying legal rights must be tested against the correct entity. A company has shares, shareholders and a board; an LLP has members, management rights and rights to surplus assets.

For a company

Shares and voting rights may be relevant.
Rights to appoint or remove a majority of directors may be relevant.
The articles, member information, agreements and ownership chain may need review.
Being a director, secretary, employee or ordinary shareholder does not by itself settle PSC status.

For an LLP

Rights to surplus assets on winding up may be relevant.
Voting and management participation rights may be relevant.
The LLP agreement and other arrangements may need review.
Being an ordinary or designated member does not by itself settle PSC status.

The same individual may hold several capacities. Their director, LLP-member and PSC roles remain separate. Identity verification for one person does not merge the underlying roles or complete every role-specific Personal Code step.

Who is the verification subject?

The PSC register can distinguish an individual from a legal entity. That distinction must be made before any identity-verification service is selected.

Person or structure	Current identity-verification position	What must be established separately
Living individual PSC	Must verify and provide the Personal Code for the PSC role within the applicable period.	Which control condition applies, the effective date and the entity’s separate notification.
Relevant legal entity or another registrable legal entity	The legal entity does not receive an individual Personal Code.	Whether it meets the registrability conditions and what information the company or LLP must report.
Officer of a corporate PSC	Companies House lists the officer requirement as a later requirement. Do not treat it as a current individual-PSC process unless commencement is confirmed.	The current corporate entry and any future commencement arrangements.
Trust or firm without legal personality	The trust or firm does not complete an individual identity check. Particular individuals may be registrable in limited circumstances.	Who exercises control and how the statutory trust-or-firm condition applies.
Beneficial owner or other controller	The label alone does not determine a current PSC identity-verification duty.	Whether the person is personally registrable under the applicable PSC legislation.

A role title does not automatically make someone a PSC

Director or company secretary

Officeholding alone does not establish PSC status. The person may separately satisfy a control condition.

LLP member or designated member

Membership or designation alone is not the PSC test. The LLP rights and arrangements must be examined.

Shareholder, member or guarantor

A holding or membership below the relevant threshold may not create PSC status, although other rights or arrangements could still be relevant.

Trustee, partner or adviser

The label itself is insufficient. The actual influence, control and statutory trust-or-firm provisions must be considered.

Do not verify the convenient person simply because their name is available. The code must belong to the individual whose PSC role is supported by the actual ownership or control position.

Direct ownership is not the only route

A person may hold rights in their own name, hold them through a legal entity or chain, act under an agreement, or exercise influence through another arrangement. The registered shareholder or LLP member is therefore not always the final answer.

Direct position

The individual personally holds the relevant shares, voting rights, LLP surplus-asset entitlement or appointment rights, or personally exercises the qualifying influence or control.

Indirect position

The rights may be held through a chain or legal entity. It must be established whether an RLE is registrable and whether an individual higher in the chain is personally registrable.

Influence through arrangements

Agreements, constitutional rights, established practices, trust arrangements or control over a firm may be relevant. A disputed or unclear position may require separate professional or legal analysis.

Identifying the Individual PSC Through Corporate, Trust and Indirect-Control Arrangements

Identifying the PSC before company formation or registration

When registering a company, the proposed ownership and control position must be examined before the incorporation information is submitted. The company-registration application and the individual’s identity-verification work are connected, but they are not the same task.

Accurately identifying an individual PSC can support the company-formation process by establishing whose particulars and Personal Code may be required. It does not create the company, allocate shares, approve the constitution or replace the incorporation application.

PSC classification supports formation

It helps identify the proposed company’s registrable ownership or control position before submission.

Formation remains a separate service

The formation destination owns the company type, name, constitution, officers, members, capital or guarantee and registration application.

Complex control needs evidence

Corporate chains, trusts, agreements and indirect holdings may require separate analysis before an accurate PSC statement can be prepared.

Where the customer’s actual destination is formation, continue with the appropriate company-formation service. For a Company Limited by Guarantee, use Company Limited by Guarantee Formation. For an LLP, use LLP Formation.

Current, transitional and future position

Current-position wording checked on 20 September 2026.

Current

Living individual PSCs

A living individual PSC must verify and provide the Personal Code for the PSC role. The entity separately identifies, confirms and reports its PSC information.

Transitional

Existing PSC timing varies

Mandatory verification began on 18 November 2025. Existing PSCs follow individual, role-specific timing. There is no single universal deadline that applies to everybody.

Future

Corporate officers and filers

Companies House lists identity-verification requirements for officers of corporate PSCs and general filers as later requirements. They must not be presented as a current individual-PSC service before commencement.

Current Companies House guidance states that identity verification is not required for a PSC who has died. The register and estate-evidence position must be dealt with through the applicable separate process.

Verification route after the person is identified

Once it is established that the subject is a living individual PSC, the person may use the free Companies House route where eligible or engage an ACSP for supported verification. Professional assistance is not compulsory.

Free Companies House route

An eligible individual can complete the official route without paying Coddan a professional verification charge. PSC classification, entity notification and other company or LLP work remain separate.

Coddan’s supported ACSP route

Where selected and agreed, Coddan identifies the individual and role, creates the verification file, coordinates the secure evidence and liveness process, reviews the result and manually submits the required verification information through its Companies House ACSP account where satisfactory and authorised.

Companies House—not Coddan or Coddan’s secure identity-verification provider—issues the Personal Code. Coddan’s client onboarding and anti-money-laundering work remain separate from Companies House identity verification.

What Coddan can establish

The entity and legal setting

Whether the matter concerns a company, CLG, LLP or another structure and which PSC framework must be applied.

The apparent control route

Whether the supplied information points to shares, voting, appointment rights, surplus assets, other influence or an indirect arrangement.

The registrable subject

Whether the available evidence points to an individual PSC, an RLE or another registrable legal entity, or requires deeper analysis.

The current verification position

Whether the identified living individual currently needs to verify and which later PSC Personal Code process is relevant.

The separate entity work

Whether formation, PSC notification, a change filing, confirmation-statement, records or governance work must be handled separately.

The safe escalation point

When an unclear chain, disputed right, trust, agreement or possible historic error needs control analysis, corrective work or legal advice.

What information should you provide?

You do not need to decide the legal conclusion before contacting Coddan. “Not known” is an acceptable answer. The following information helps us identify what must be examined.

Entity details

Registered or proposed name, company or LLP number if available, entity type, jurisdiction and whether it is being formed or already exists.

People and legal entities

Names of the individuals, shareholders, members, corporate bodies, trustees, partners or other persons in the ownership or control arrangement.

Rights and percentages

Shares, voting percentages, LLP surplus-asset rights, appointment or removal rights, management rights and any other stated influence.

Supporting documents

Articles, LLP agreement, member information, ownership chart, shareholder or voting agreement, trust or firm information and relevant correspondence.

Dates and existing records

When the rights began or changed, what Companies House currently shows and whether any formation, PSC or confirmation-statement process is under way.

Any uncertainty or dispute

Tell us if ownership, voting, authority, control, consent or the existing PSC entry is uncertain or disputed. Do not make the conclusion yourself.

This section does not transmit an enquiry. Contact Coddan through the normal website contact details. Do not send an actual Personal Code, password, company authentication code or sensitive unredacted identity evidence through a general enquiry.

What identity verification does not decide

Identity verification does not decide who owns or controls the company or LLP. It does not create PSC status, determine a nature of control, make an RLE registrable, validate an ownership chain or prove that an entity’s PSC filing is accurate.

It also does not create a directorship, LLP membership, trusteeship, partnership interest or filing authority; complete incorporation; notify the entity’s PSC information; correct the Companies House register; or resolve disputed ownership or control.

Who is responsible for each part?

The company or LLP

Must identify and report its registrable PSC information accurately and keep the underlying entity work separate from the individual’s identity check.

The individual

Must provide accurate information, complete their personal verification where required and protect and use their Personal Code through the applicable PSC process.

Coddan

Undertakes only the classification, verification, coordination, filing or advisory work it is authorised and engaged to perform. Coddan does not issue Personal Codes or decide a disputed legal question.

Companies House and advisers

Companies House controls its services, codes, filings and register. Legal or other professional advice may be required where rights, registrability, authority or control are disputed.

Frequently asked questions

Does every shareholder have to verify as a PSC?

No. The person must meet at least one applicable PSC condition. A shareholding of more than 25% is a common route, but indirect holdings and other rights may also matter.

Does every company director have to verify as a PSC?

No. Directors have their own identity-verification requirement, but directorship alone does not make the person a PSC. The PSC conditions must be considered separately.

Does every LLP member or designated member verify as a PSC?

No. LLP membership and PSC status are separate. A member may be a PSC where the relevant surplus-asset, voting, management or other control condition is met.

Is every beneficial owner an individual PSC?

Not automatically. “Beneficial owner” can be used broadly. The person must be registrable under the applicable PSC legislation before the individual PSC verification process is selected.

Does a corporate shareholder complete identity verification?

A corporate body does not receive an individual Personal Code. It must be established whether it is an RLE or another registrable legal entity and whether an individual elsewhere in the ownership chain is registrable.

Must an officer of a corporate PSC verify now?

Companies House currently lists identity verification for officers of corporate PSCs as a later requirement. It must not be presented as operational until commencement and the applicable procedure are officially confirmed.

Does every trustee or partner have to verify?

No. Trust and firm arrangements are relevant only in particular statutory circumstances. The actual control position must be examined before identifying an individual PSC.

Can the same person be both a director or LLP member and a PSC?

Yes. The individual normally keeps one Personal Code but provides it separately through the process applying to each affected role. The roles and their underlying legal status remain separate.

Does identity verification prove the nature of control?

No. It confirms identity within the Companies House framework. The ownership or control evidence determines whether the person is a PSC and which nature of control applies.

What if nobody appears to meet a PSC condition?

The entity’s PSC information cannot simply be left blank. The applicable official PSC statement and the underlying analysis must be considered separately. Do not identify an individual merely to fill the register.

Can Coddan determine a disputed control position through identity verification?

No. Coddan can identify the apparent issues and review evidence within the agreed scope, but disputed ownership, control, authority or registrability may require separate legal or professional analysis.

What if the wrong person is already shown as a PSC?

Do not use identity verification or another person’s Personal Code to validate the entry. The real control position, original filing and appropriate entity or corrective route must be examined.

Tell us who appears to own or control the entity

Provide the company or LLP, the people and legal entities involved, the apparent rights and any relevant documents or uncertainty. Coddan can identify the appropriate classification, verification and entity-service route without asking you to make the legal conclusion first.

Discuss who may need to verify

PSC Ownership, Voting Rights and Control Verification Guide.

Establish whether ownership, voting rights or other control conditions make an individual a PSC before selecting the appropriate identity-verification and Companies House route.

Follow the PSC ownership and control journey from identifying the entity and relevant rights through establishing the registrable subject and selecting the appropriate verification route.