Regulation 30A of the Money Laundering Regulations 2017 requires an accountancy practice to check the Companies House register before taking on a company, LLP or eligible Scottish partnership client, and again when it carries out CDD or ongoing monitoring later. If what the firm has learned about the client’s beneficial owners differs materially from the PSC register, it must report the discrepancy to Companies House. Since 1 April 2023 only “material” discrepancies, those that could reasonably be linked to money laundering, terrorist financing or concealing details of the client’s business, need reporting.

What exactly does regulation 30A require?

The duty has two stages:

  • Before the relationship starts. Regulation 30A(1) requires the firm to collect an excerpt of the register showing the beneficial ownership information held, or establish that there is none, before establishing a business relationship with a company subject to Part 21A of the Companies Act 2006, an unregistered company, an LLP, an eligible Scottish partnership, a registrable trust or a registered overseas entity. Regulation 30A(2) then requires it to report any material discrepancy it finds between the register and information that otherwise becomes available to it while establishing the relationship.
  • During the relationship. Regulation 30A(2A) repeats the excerpt requirement whenever the firm takes measures to carry out CDD or ongoing monitoring, including enhanced measures, after the relationship has begun, and regulation 30A(2B) repeats the reporting duty.

Regulation 30A(3) says where the report goes: to the registrar of companies for companies, unregistered companies, LLPs and eligible Scottish partnerships; to HMRC for trusts; and to the registrar for England and Wales for overseas entities. This page deals with the Companies House route. The wider verification work is covered in verifying beneficial owners.

What makes a discrepancy “material”?

Schedule 3AZA, inserted from 1 April 2023, sets the test. A discrepancy is material if, by its nature and having regard to all the circumstances, it may reasonably be considered to be linked to money laundering or terrorist financing, or to conceal details of the business of the customer. It lists the forms a material discrepancy may take:

  • a difference in name;
  • an incorrect entry for nature of control;
  • an incorrect entry for date of birth;
  • an incorrect entry for nationality;
  • an incorrect entry for correspondence address;
  • a missing entry for a PSC;
  • an incorrect entry for the date the individual became a registrable person.

Companies House guidance adds that the firm does not need to decide whether concealment was deliberate. The question is whether the information could objectively be considered to conceal details of the PSC from the register. Its examples include a person holding more than 25% of the shares being shown only as having significant influence or control, a 50% holder recorded in the “more than 50% but less than 75%” band, and a month or year of birth that differs from the passport. The PSC categories themselves are explained in persons with significant control.

What does not need to be reported?

Companies House lists cases that are not reportable, including:

  • spelling errors, shortened names (Jim for James) and minor address variations (Glos Rd for Gloucester Road);
  • nationality given as English, Welsh, Scottish or Northern Irish where the register shows UK;
  • information the firm holds that is not required on the register;
  • a discrepancy already reported, or one resolved before the report is submitted;
  • a difference caused only by the gap between the Companies Act definition of a PSC and the MLR definition of a beneficial owner.

Addresses need care. The register shows a service address, which need not be the home address, so a client’s home address differing from the register is not in itself a discrepancy. Companies House says reports should only compare the same type of address.

Where a discrepancy is not material, Companies House suggests the firm may advise the company to file a correction, and says it may be sensible to keep a short note of the reasoning in case the supervisor asks. That note belongs with the CDD records described in AML record keeping.

When should the register be rechecked?

Companies House leaves the timing of ongoing checks to a risk based approach informed by supervisor guidance, but suggests checking when the company says its PSC details have changed, when the firm has information or suspicion that they have changed, and when carrying out enhanced due diligence on beneficial ownership. In practice an annual accounts engagement, where the firm reviews the share register and any share transfers, is a natural point. See ongoing monitoring.

Material discrepancies should be reported as soon as they are identified. Companies House says bulk reporting is not allowed: firms must not hold reports back and submit them in batches.

How is a report made?

Reports are made through Companies House’s online service. The firm needs:

  • which condition the discrepancy relates to (money laundering, terrorist financing or concealment, or a combination);
  • the company number;
  • the type of material discrepancy;
  • the information on the register the firm believes is wrong, and what it believes should be shown;
  • any other supporting information, and for a missing PSC, why the person qualifies.

A separate report is needed for each PSC. Where a PSC’s details are protected, the online service cannot be used and Companies House asks firms to telephone instead. Regulation 39(1) allows a firm to rely on a suitable third party to carry out the regulation 30A measures, but it remains liable for any failure; see reliance on third parties.

What happens after a report, and what can the client be told?

Regulation 30A(5) requires Companies House to take such action as it considers appropriate to investigate and, if necessary, resolve the discrepancy in a timely manner. Regulation 30A(6) makes the report material excluded from public inspection. Companies House says it will not tell the company who made the report or give the reporter updates.

A discrepancy report is not a suspicious activity report. Companies House says neither should be used in place of the other, some cases need both, and firms should not tell Companies House that a SAR has been made. Nothing in regulation 30A prevents the firm asking the client to correct its register, but if the discrepancy has also led to a SAR, any conversation must avoid disclosing that, under section 333A of the Proceeds of Crime Act 2002. See suspicious activity reports and tipping off. Regulation 30A(4) also excuses reporting information protected by legal professional privilege.

How does this work in practice?

Illustration only. A practice takes on Bridge Trading Ltd. The PSC register shows one PSC, Mrs A, holding more than 75%. The share register the firm obtains shows Mrs A with 60% and her business partner Mr B, resident abroad, with 40%. Mr B is not on the register at all.

  1. The firm saves the register excerpt to the CDD file before signing the engagement letter.
  2. Mr B qualifies as a PSC under the more than 25% shares condition, so this is a missing entry and an incorrect nature of control for Mrs A.
  3. Mrs A says Mr B “prefers to stay off the record”. That points to concealment, so the discrepancy is material and is reported online, with two reports, one for each PSC.
  4. The MLRO separately considers whether the explanation gives grounds for suspicion and a SAR.
  5. Mr B is identified and verified as a beneficial owner before the firm acts.

What are the common mistakes?

  • Not keeping the register excerpt, so the firm cannot show it checked before the relationship began.
  • Reporting trivial differences, or not reporting material ones because the client promised to file a correction.
  • Treating a discrepancy report as a substitute for a SAR, or the other way round.
  • Comparing the client’s home address with the register’s service address.
  • Rechecking only at onboarding and never during later CDD.

Solar Protect runs fee protection schemes for accountancy and bookkeeping practices. See how our accountant schemes work or read fee protection schemes for accountants.

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Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.