CIC Persons with Significant Control (PSC)

Written by Ben Ahern, Founder of CIC Tools and Co-founder of Homeless Aid UK CIC. Last updated 17 September 2026.

Who counts as a PSC in a CIC limited by guarantee, how the “more than 25%” test works without shares, and what to file with Companies House.

Quick answer

A person with significant control is anyone who holds more than 25% of the votes, can appoint or remove a majority of the directors, or otherwise has significant influence over the company. In a guarantee CIC the usual test is voting rights: one, two or three equal members are all PSCs; with four or more equal members no one may meet the test. Tell Companies House about any change within 14 days.

Planning your CIC? Get the free starter checklist.

What is a PSC?

The PSC regime exists so that the public register shows who really controls each UK company. Every company, including every CIC, must identify its PSCs, report them to Companies House and keep the information up to date. A CIC limited by guarantee has members instead of shareholders, so control is measured through voting rights and influence rather than shares.

PSCs are usually individuals. Where a company or other legal entity controls your CIC, it is recorded as a “relevant legal entity” instead.

The PSC conditions

A person is a PSC if they meet one or more of these conditions.

  1. 1

    More than 25% of the shares

    Share companies only. A CIC limited by guarantee has no shares.

  2. 2

    More than 25% of the voting rights

    The usual test for a guarantee CIC: count members' votes.

  3. 3

    Right to appoint or remove a majority of the directors

    Check the articles for any such power.

  4. 4

    Significant influence or control over the company

    A founder everyone defers to can meet this even with fewer votes.

  5. 5

    Significant influence or control over a trust or firm that meets one of the above

    Rare for small CICs.

Source: gov.uk: people with significant control (PSCs).

Who is a PSC in your CIC?

PSC outcomes by number of equal members
Members with equal votesResult
1 memberThat person is a PSC (100% of votes).
2 equal membersBoth are PSCs (50% each).
3 equal membersAll three are PSCs (about 33% each).
4 equal membersNo one meets the 25% test on votes alone (25% each is not "more than" 25%). Check condition 4.
5 or more equal membersUsually no PSC on votes. Consider whether anyone has significant influence.

Voting rights are only the first test. Someone who holds fewer votes can still be a PSC if they have the right to appoint or remove most of the directors, or if in practice the company does what they say. Directors are not automatically PSCs; being a director and being a member are different roles, though in small CICs the same people usually hold both.

Designing your CIC for shared control

Some founders prefer a structure where no single person is a PSC, because it signals shared ownership to funders and the community. Four or more members with equal votes achieves that on the voting test, provided nobody has other rights of control. This is a design choice, not a legal requirement, and it has trade-offs: more members means more people to keep engaged and to verify.

Whatever you choose, be honest in the filing. Reporting “no PSC” when a founder in fact controls the CIC is a false statement to Companies House. See our guide to director structure for how boards and members fit together.

Do you still need to keep a PSC register?

Companies have historically had to keep their own PSC register as well as reporting to Companies House. The Economic Crime and Corporate Transparency Act 2023 is moving company registers onto the central register held by Companies House, and the changes are being switched on in stages. Gov.uk's PSC guidance currently describes the reporting duties to Companies House without setting out a local register requirement. Until Companies House confirms the position for your company, keep a simple record of your PSC decisions and dates; it costs nothing and answers any question later.

Want help with the paperwork?

We write your CIC36 and Articles of Association from your answers.

CIC Formation Pack — £29 one-off

Start my CIC freeSee what's included

For CICs limited by guarantee. Start free, pay when you're ready to download. Companies House charges £115 separately.

How to file with Companies House

At incorporation

Your first PSCs are part of the registration application. For each PSC you give their name, date of birth, nationality, address, the conditions met and, for voting rights, the band: more than 25% up to and including 50%, more than 50% and less than 75%, or 75% or more. Since 18 November 2025 each PSC also needs a verified identity and personal code.

After incorporation

  • New PSC: form PSC01 within 14 days of confirming the change.
  • Change to a PSC's details: form PSC04 within 14 days.
  • PSC ceases: form PSC07 within 14 days.
  • Every year: confirm the PSC information is correct in the confirmation statement. See our annual requirements guide.

Filing is free online through Companies House WebFiling.

Source: gov.uk PSC guidance and gov.uk identity verification guidance.

Penalties

When to review PSC status

  • A member joins or leaves, changing everyone's share of the votes.
  • The articles are changed, for example to give someone the right to appoint directors.
  • A founder steps back, or a new person starts making the decisions in practice.
  • Before every confirmation statement.

Common mistakes

  • Assuming guarantee companies have no PSCs. They do; the test is votes and influence.
  • Listing every director as a PSC. Directors are only PSCs if they meet a condition.
  • Treating 25% as “more than 25%”. Four equal members are not PSCs on votes alone.
  • Ignoring the influence test. A founder who controls decisions is a PSC whatever the vote count.
  • Missing the 14-day deadline after a member joins or leaves.
  • Forgetting identity verification for a new PSC.

Frequently asked questions

Does a CIC limited by guarantee need a PSC?
Every company must identify its PSCs, and a CIC limited by guarantee is no exception. Because there are no shares, the test is usually voting rights: a member with more than 25% of the votes is a PSC. If no one meets any condition, the company reports that instead.
What does "more than 25%" mean in practice?
Exactly 25% does not count. Four members with equal votes each hold 25%, so none is a PSC on voting rights alone. Three members with equal votes each hold about 33%, so all three are PSCs.
Can a CIC have no PSC?
Yes. If no individual meets any of the conditions, for example five equal members with no one exerting significant influence, the company records that it has no PSC and tells Companies House.
How do I tell Companies House about a PSC?
Your first PSCs are declared in the incorporation application. Later, notify a new PSC with form PSC01, a change with PSC04 and a person ceasing with PSC07, each within 14 days of confirming the change. You can file online through Companies House WebFiling.
What are the penalties for not reporting a PSC?
Not complying with the PSC rules is a criminal offence. Gov.uk says a person who refuses to provide PSC information or gives false details "could get a 2 year prison sentence, a fine or both".
Do PSCs have to verify their identity?
Yes. Since 18 November 2025, PSCs must verify their identity with Companies House and provide their personal code. New PSCs verify when they are reported. Existing PSCs have a 14-day window whose dates depend on when the company was registered and whether they are also a director; check gov.uk for your date.

Quick question before you read on

Interested in an online guided CIC setup course?

Ben (who runs CIC Tools and his own CIC) is thinking about turning his experience into a step-by-step video course: setting up, staying compliant, and finding your first funding. He'll only build it if enough founders want it - your answer is the vote.

About the author

Ben Ahern is the founder of CIC Tools and co-founder of Homeless Aid UK CIC. He has filed PSC information for his own CIC and helps founders get the incorporation application right first time.

Free checklist

Planning your CIC?

Get the free CIC Starter Checklist. Find out what to prepare, which documents you need and what happens after registration.