Regarding the new regs. about reporting discrepancies with PSCs (see below):
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Are there any plans to provide a means to do this under the API?
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Whether or not the answer to (1) is “yes” I see that currently there is a link given to report these: Report a PSC register discrepancy with Companies House. Is there any means to automate filling these in? For example providing at least some of these (organisation, type of entity, address / contact) via GET / POST parameter to this URL?
It may be that this form is very infrequently needed. However the form has quite a number of fields. We’d be directing clients to complete this in cases where much of this information is already known so we could make this significantly easier to complete by pre-filling some fields. This would also encourage compliance.
As far as we can see there doesn’t appear to be any regulation requiring that this is reported by a particular mechanism, only that you must report and what must be reported. If the smart survey form was found to be onerous by our clients we might be tempted not to use this method.
- For incorrect information outwith the scope of the regulations above what is the appropriate way to report incorrect information (e.g. for company address / name / officer)? Is it by using the “Feedback form” / “Is there anything wrong with this page?” link appearing on CH Beta e.g.:
https://beta.companieshouse.gov.uk/help/feedback?sourceurl=https://beta.companieshouse.gov.uk/company/{some company number}
I’m not referring to issues which appear to be with the API, just incorrect information as per question (2).
Thanks!
What I understand of the regulations:
From 10th Jan 2020 “obliged entities” (essentially most entities entering into a business relationship with a company) have a duty to report to “the registrar” if they know of any “discrepancy” (anything apart from insignificant typos) between what’s on the Companies House PSC register and what they know to be correct. This must be done in a “timely manner” - with exemptions for legal priveledge / confidentiality however.
Refs:
Companies House Guidance - report a discrepancy:
The Money Laundering and Terrorist Financing (Amendment) Regulations 2019:
http://www.legislation.gov.uk/uksi/2019/1511/contents/made
Info from EU on Money Laundering and 5th directive (links in page):