Discrepancy reporting

What PSC discrepancy reporting is under regulation 30A of the UK Money Laundering Regulations, what counts as material, what doesn't, and how to report.

What is discrepancy reporting?

Discrepancy reporting is the duty on regulated firms to tell Companies House when the beneficial ownership information on its register does not match what they found during customer due diligence. It is set out in regulation 30A of the Money Laundering Regulations 2017 (MLRs). Since 1 April 2023, you only report material discrepancies.

The duty applies whatever level of due diligence you use, including simplified due diligence (reg 37(2)(a)).

The UK rules

RuleWhat it saysWhere
Check the registerBefore establishing a business relationship with a company, LLP, eligible Scottish partnership, unregistered company, registered trust or registered overseas entity, collect an excerpt of the register’s beneficial ownership information, or confirm none is heldReg 30A
ReportReport a material discrepancy between the register and the information otherwise available to you during your due diligenceReg 30A
Keep checkingThe duty also applies during CDD and ongoing monitoring once the relationship has startedReg 30A
Who receives itCompanies House for companies, LLPs and partnerships; HMRC for trusts; Companies House for overseas entitiesReg 30A
Legal privilegeYou need not report information protected by legal professional privilegeReg 30A
What is materialA discrepancy that could reasonably be considered linked to money laundering or terrorist financing, or to conceal details of the client’s businessSch. 3AZA

Source: MLR regulation 30A and Schedule 3AZA.

What counts, and what doesn’t

Usually material (report it)Not reportable
A different name, or a missing part of a surnameSpelling errors and shortened names
An incorrect nature of controlMinor address variations
A wrong month or year of birth“UK” on the register where the person gave English, Welsh, Scottish or Northern Irish
A wrong nationalityDifferences caused by the different PSC and beneficial owner definitions
A significantly different correspondence addressDiscrepancies already reported, or resolved before you report
A missing PSC or registrable beneficial owner
A wrong date of becoming a registrable person

Based on Companies House guidance. A discrepancy in a listed form must still meet the “material” test in Sch. 3AZA. For minor errors, you can suggest the company corrects its own register.

How to report

  • Use Companies House’s online discrepancy service. You need the company number (or overseas entity ID), the type of discrepancy, what the register says and what you believe is correct.
  • Make a separate report for each PSC or beneficial owner. Bulk reporting is not allowed.
  • Report as soon as you find the discrepancy.
  • Companies House investigates. It does not tell the company who reported it, and it does not send updates.

Source: GOV.UK: report a discrepancy about a beneficial owner on the PSC register.

What a small firm should do

  1. Download the PSC register entry for every company client before you start, and keep it on file.
  2. Compare it with what you learn when you map the beneficial owners.
  3. Decide whether a difference is material, record your reasoning, and report if it is.
  4. Repeat the check when you refresh CDD during the relationship.

A discrepancy can also be a reason to look harder at the client. If it suggests concealment, consider enhanced due diligence and whether a suspicious activity report is needed.

Frequently asked questions

Do I have to report every difference on the PSC register?

No. Since 1 April 2023, only material discrepancies are reportable: those that could reasonably be linked to money laundering or terrorist financing, or to concealing details of the client’s business. Spelling errors and minor address differences are not.

Does the company find out I reported it?

Companies House says it does not tell the company who made the report.

Is a discrepancy report the same as a SAR?

No. A discrepancy report goes to Companies House and is about the accuracy of the register. A SAR goes to the National Crime Agency and is about suspected money laundering. Sometimes you may need both.

How AML Buddy helps

You can verify each director, PSC and beneficial owner with their own AML Buddy link: ID document and selfie, address match, and sanctions, PEP and adverse media screening, with a timestamped report per person. Comparing results with the register and reporting discrepancies stays with your firm. Company (KYB) checks are coming soon. See pricing.

Discrepancy reporting

Checking the people behind a company?

Verify each director, PSC and beneficial owner with AML Buddy: one secure link and one report per person. Company (KYB) checks are coming soon. £5.40 a check inc. VAT, 5 free checks to start.