Dear Member,

Guidance Note: New Companies House Requirements (ID Verification & PSCs)

To: Pharmacy Contractors / Company Directors

Subject: Mandatory Identity Verification and Changes to Ownership Registers

Recent updates to the Economic Crime and Corporate Transparency Act have introduced strict new verification rules for company directors and owners. The "record it in a binder" approach is no longer sufficient; the focus has shifted to digital, verified accountability.

Below is a summary of the key actions required based on the latest government guidance.

1. Mandatory Identity Verification (New Legal Requirement)

Ref: Verifying your identity for Companies House

The Change: Companies House is introducing a "verify first" system to prevent fraud. All Directors and People with Significant Control (PSCs) must prove who they are.

Your Action Plan:

1. Get Verified: You will need to verify your identity using the GOV.UK One Login service (using a passport or driving licence).
2. Obtain Your Code: Successful verification generates a unique Companies House Personal Code.
3. Share Securely: You must provide this code to your authorised agent (e.g., your accountant or PharmaPlus if they handle filings) or use it yourself when filing. Without this code, you cannot be appointed as a new director or file certain updates.

Deadlines:

• New Appointments: Must verify before their appointment is registered.
• Existing Directors: There is a transition period. You will likely be required to verify before filing your next Confirmation Statement.

2. Register of People with Significant Control (PSC)

Ref: PSC Summary Guidance & Statutory Guidance PDFs

The Basics: A PSC is anyone who meets one of the following conditions:

• Holds more than 25% of shares.
• Holds more than 25% of voting rights.
• Has the right to appoint or remove the majority of the board of directors.
• Otherwise exercises "significant influence or control" (common in family-run pharmacies where a non-director family member makes key decisions).

The Process Change: Previously, companies kept a "local register" (a physical folder or file) and updated Companies House annually.

• New Rule: You must file changes to PSCs directly with Companies House within 14 days of the change.
• Central Register: The central public register at Companies House is now the definitive record.

Required Action:

• Review: Check your current PSC filing on the Companies House Beta service. Does it accurately reflect the current ownership of your pharmacy?
• Update: If you transfer shares, bring in a partner, or restructure, you must report this immediately.
• Corporate Owners: If your pharmacy is owned by another company (e.g., a holding company), that entity is a "Relevant Legal Entity" (RLE) and must be recorded in the register.

Summary of Risks

Failure to comply with these rules is a criminal offence. Practically, if your ID is not verified, Companies House will block your filings (including your Confirmation Statement), which can lead to your company being struck off the register and the pharmacy contract being put at risk.

Regards

PharmaPlus