Identity verification starts after the registrable subject is identified

A corporate shareholder, corporate LLP member, RLE, trust or firm does not receive an individual Personal Code. Nor does every director, officer, trustee, beneficiary, settlor, protector, partner or beneficial owner automatically become an individual PSC.

The relevant company or LLP must first establish how the statutory PSC conditions apply to the real structure. Only then can the individual identity-verification requirement be attached to the correct natural person.

Different people and entities must not be treated as interchangeable

The label used in commercial documents may not be the answer under the PSC regime. Coddan may need to separate each of the following before recommending verification.

What the control analysis may need to distinguish

There is no safe universal formula that starts at the top of every ownership chart and automatically identifies the correct individual PSC.

Corporate ownership chains and RLEs

Where a company, LLP or overseas legal entity appears in the chain, Coddan may need to establish its legal form, jurisdiction, ownership, voting and appointment rights, whether it is subject to relevant disclosure requirements and whether it is registrable under the applicable PSC regime.

The highest natural person shown in a corporate chart is not automatically the registrable PSC. The statutory path, intervening entities and rights must support the conclusion.

Company and LLP control tests are not word-for-word substitutes

A company analysis may focus on shares, voting rights and board-appointment rights. An LLP has no share capital in the same sense. Its adapted PSC conditions and governing arrangements must be considered on their own terms.

Trusts and firms without legal personality

The trust-or-firm condition applies in limited and fact-sensitive circumstances. The existence of a trust, partnership or nominee arrangement does not automatically make every connected person a PSC.

Coddan may need to review who holds the relevant company or LLP rights, how trustees or partners act, whether another person exercises significant influence or control over the activities of the trust or firm, and what the governing instruments actually permit.

Unusual, disputed or legally uncertain trust and firm arrangements may require independent legal or specialist advice. This page does not provide a trust-law or partnership-law determination.

Nominee, voting, partnership and management arrangements

The person named on a register may not be the only person whose rights matter. Agreements can allocate voting, appointment, economic or management rights differently from the apparent legal title.

Coddan must examine the arrangement and the applicable statutory rules. It must not assume that a nominee is never a PSC, that the principal is always the PSC or that a beneficial owner label settles the registration question.

Complex PSC identification during company formation

A proposed company may have corporate shareholders, an RLE, indirect ownership, a trust or firm arrangement or another multi-layer structure. Identifying the correct PSC or registrable legal entity can support an accurate company-formation, registration or incorporation application.

The formation ecosystem continues to own the incorporation application, company structure, subscribers or members, articles, capital or guarantee arrangements, registered office, director appointments and the registration outcome. PSC analysis and identity verification do not incorporate the company.

Current identity-verification boundary

Where the same confirmed individual is also a director or LLP member, the other role has its own Personal Code process. One role connection does not complete another.

Verification follows identification

Once an individual PSC has been identified, an eligible person may use the free Companies House verification route. Professional ACSP assistance is optional.

Where Coddan’s supported route is suitable and agreed, Coddan creates the individual verification file, uses its secure identity-verification provider, reviews the evidence and result and, where satisfactory and authorised, manually submits the required information through its Companies House ACSP account.

Companies House—not Coddan or the provider—issues the Personal Code. Coddan’s onboarding, anti-money-laundering work, control analysis, identity verification, code use and entity notification remain separate.

What Coddan can establish

Within the agreed scope, Coddan can map the supplied ownership and control chain, distinguish individuals and legal entities, review relevant instruments and identify an apparent individual PSC, RLE or unresolved issue. Confirmed identity-verification and notification work can then be coordinated separately.

What information should you provide?

“Not known” is an acceptable answer. You do not need to decide whether an entity is an RLE, a majority stake exists, an individual is registrable or legal advice is required.

This section does not transmit an enquiry. Use Coddan’s normal website contact details. Do not place an actual Personal Code, password, authentication code or sensitive unredacted identity evidence in a general website enquiry.

What this service does not decide

Coddan does not create ownership or control, validate an incomplete or unauthorised arrangement, treat identity verification as control analysis, issue Personal Codes or guarantee Companies House acceptance.

A disputed beneficial-ownership, trust, partnership, authority or registrability question may require legal or specialist advice. Companies House, the entity, a court and other professionals retain the decisions within their respective control.