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2026-08-27 00:00 Counterparty Checks

Counterparty in England and Wales: what can be established

England and Wales operates one of the most transparent corporate disclosure regimes in the world. Control — who holds shares, who directs the company, who has registered a charge over its assets — is recorded in public registers and retrievable without a court order or a declaration of legitimate interest. The question is not whether the record exists, but what it contains and where it stops.

The angle here is control: who actually controls the counterparty, what a shareholder can enforce, and what the register shows about the chain between the registered name and the person giving instructions.

What the register showsRegistered officers, shareholders, persons with significant control (PSC), filed accounts, charges over assets, and insolvency status. Source: Companies House · extracted 2026-03-10 Cost of accessFree of charge. Companies House data is published under OGL v3.0 — redistribution with attribution is permitted. Source: Companies House · extracted 2026-03-10 PSC regimePersons with significant control are disclosed publicly by name, nature of control and date of notification. This is a confirmed exception to the post-CJEU C-37/20 default across EU jurisdictions. Source: Companies House · extracted 2026-03-10 What the register does not showBeneficial ownership above the PSC layer where a non-UK holding company sits in the chain. The register records the immediate PSC; it does not trace the chain through foreign entities.
Source: Companies House · extracted 2026-03-10

What Companies House records about control

Companies House holds the statutory register for England and Wales. Every private and public company must file: incorporation documents, current and resigned officers, the confirmation statement (which includes the shareholder list), persons with significant control, and annual accounts.

The PSC register is the primary instrument for establishing control. A person qualifies as a PSC if they hold more than 25% of shares or voting rights, have the right to appoint or remove a majority of directors, or otherwise exercise significant influence or control. The register records the nature of control, the date of notification, and — for individuals — name, month and year of birth, nationality, and country of residence.

Registered charges are filed separately within Companies House. Each charge entry records the date of creation, the date of registration, the chargee, and the assets or property charged. The underlying charge document is retrievable from the same platform.

Filed accounts are available for the majority of companies. Micro-entity and small company accounts are abbreviated; full accounts are filed by larger entities. The depth of financial disclosure depends on the company's size classification at the time of filing.

Officers (current and resigned)
Companies House
Free
A
Shareholders (confirmation statement)
Companies House
Free
A
Persons with significant control
Companies House
Free
A
Registered charges
Companies House
Free
A
Filed accounts
Companies House
Free
A
Insolvency status
Individual Insolvency Register + The Gazette
Free
A
Land and title (property ownership)
HM Land Registry
£7 per title register
A
Licences and regulatory status
FCA and sector regulators
Free
B
Vehicle and equipment ownership
DVLA
Not disclosed
C

Persons with significant control: the PSC layer

The PSC regime came into force in April 2016. It is a statutory disclosure obligation, not a voluntary filing. Non-compliance is a criminal offence. This distinguishes it from beneficial ownership registers in most EU jurisdictions, where post-CJEU C-37/20 access is restricted or suspended.

The PSC register is public and free of charge. What a report adds is the structured path: retrieving the confirmation statement, reading the PSC entries against the shareholder list, cross-referencing officer history, and identifying where the chain continues through a Relevant Legal Entity (RLE) rather than an individual.

Where a corporate entity holds the PSC position, the register records it as an RLE and requires that entity to be subject to its own disclosure obligations. If the RLE is a non-UK company, the chain does not continue automatically in the Companies House record. That is the ceiling of this layer.

Charges, encumbrances and financial position

The register of charges is part of Companies House. A charge must be registered within 21 days of creation. Failure to register renders the charge void against a liquidator and creditors. The register therefore reflects the secured creditor landscape with a defined statutory lag.

Each charge entry states whether the charge is outstanding or satisfied. The underlying document — the instrument creating the charge — is filed and retrievable. It describes the assets covered, the conditions, and the parties.

Filed accounts provide a snapshot of financial position at the balance sheet date. For companies filing full accounts, the notes disclose related-party transactions, director remuneration bands, and significant shareholdings. For micro-entity and small company accounts, disclosure is abbreviated and the profit and loss account is not filed publicly.

Insolvency status is checked across two sources: the Individual Insolvency Register (for individuals associated with the company) and The Gazette (for corporate insolvency notices including winding-up petitions, administration orders, and liquidation notices). A negative result in either register does not confirm the absence of a filed petition; it confirms the absence of a published notice at the time of retrieval.

Land and property: HM Land Registry

Where the counterparty holds registered title to property in England and Wales, HM Land Registry records the registered proprietor, the class of title, and any charges or restrictions on the title. A title register costs £7 per title (fee effective from 9 December 2024). A name search under form PN1 costs £15 and is submitted in paper form.

The Land Registry record shows the registered proprietor at the date of registration. It does not show beneficial ownership where legal and beneficial title are split — for example, where a company holds legal title as nominee for another party.

Source: HM Land Registry · extracted 2026-03-10

Sanctions and regulatory status

The OFSI consolidated list records financial sanctions designations under UK sanctions regimes. It is public and free of charge. A match on the OFSI list is a hard stop for any transaction subject to UK sanctions law.

Regulatory licences and permissions are held by sector regulators. The Financial Conduct Authority (FCA) maintains a public register of authorised firms and individuals. Other sectors — legal services, healthcare, construction — are regulated by separate bodies. There is no single unified licence register for England and Wales. Coverage at this layer is rated B: the information exists, but retrieval requires identifying the relevant regulator for each activity.

Source: OFSI consolidated list · extracted 2026-03-10

The limit of what the sources allow

Companies House is a filing registry, not a verification authority. It records what has been filed. It does not verify that the information filed is accurate. A director can be registered who has not consented; a PSC can be listed who disputes the designation; a shareholder list can be out of date if the confirmation statement has not been updated.

The PSC register traces control to the first qualifying individual or RLE. Where the chain continues through a non-UK holding company, the record stops at that entity. The identity of the persons controlling that entity is not in the Companies House record.

Filed accounts reflect the position at the balance sheet date. They do not show transactions after that date, off-balance-sheet arrangements, or intra-group positions that are eliminated on consolidation.

The register of charges reflects registrations made within the statutory window. A charge created but not yet registered — or a charge rendered void for non-registration — does not appear as outstanding.

Land Registry records show registered title. They do not show beneficial ownership where legal and beneficial title are separated by a trust or nominee arrangement.

These are not gaps in the report. They are the defined ceiling of the public record in this jurisdiction. The report states what was found, what was not found, and at which point the source stops.