Updating persons with significant control after incorporation

PSC changes after incorporation: the deadline to tell the company, and the separate deadline for the company to tell CAC.

2 min readBy the Docufy editorial team

Quick answer

When significant control over a company changes hands, the person gaining it must tell the company within 7 days of gaining significant control. The company then has within one month of receiving the information to pass that on to CAC.

Person tells company
within 7 days of gaining significant control
Company tells CAC
within one month of receiving the information
Applies to
any change, not just the original registration
Can affect
up-to-date annual returns and PSC information
On this page

Persons with significant control are not a box you tick once at registration. The record has to move every time control actually shifts.

Significant control can change long after registration

A company's significant-control picture rarely stays fixed. An investor buying a majority stake in a funding round can trigger it. So can a shareholder quietly building up a stake over several small purchases, years after incorporation.

The trigger is the change in control itself, not any one kind of transaction. A sale, an inheritance, or a change in voting arrangements can all qualify.

Deal teams often focus on the commercial paperwork and forget this separate duty entirely. Build a PSC check into your closing checklist for any transaction that shifts real control.

The deadline for the person to tell the company

Once someone gains significant control, they must tell the company within 7 days of gaining significant control. This duty sits with the person gaining control. It does not sit with the company chasing them for it.

Build this into any deal that shifts real control. Add it next to the commercial paperwork. A fast-moving deal can close without anyone thinking about this separate duty at all.

The deadline for the company to tell CAC

Once the company has that information, it has within one month of receiving the information to pass it on to CAC. Think of the two deadlines as one chain, not two separate dates.

The first clock starts once control actually changes. The second starts only once the company knows about it.

A company that hears about a change informally should still treat that as the moment its own clock starts. Waiting for a formal letter is not required.

Why this record affects filings that have nothing to do with PSC

Up-to-date annual returns and PSC information before CAC processes most other post-incorporation filings. That covers a change of directors and a registered address update alike.

A company can be fully current on its annual returns and still get stuck. Its significant-control record may be the part that has gone stale. Check both records, not just the more familiar one.

Keeping a simple log of both dates

A short internal log, noting who gained significant control, when they told the company, and when the company told CAC, costs little to keep and saves a scramble later.

Review it whenever you are about to make an unrelated CAC filing, since a gap here can block something that looks completely unconnected on the surface. Director and shareholder details CAC needs covers the related record you are already keeping for other filings.

You can start a CAC company registration if you have not yet incorporated. The CAC registration hub links the rest of this series on post-incorporation changes, including PSC disclosures when you register a company for how this record starts out.

Questions people ask

Is this different from declaring PSC information when I first register?

The declaration at registration is a one-off snapshot. This is the ongoing duty that applies every time significant control actually changes afterwards. See PSC disclosures when you register a company for the registration-stage rule.

Who has the duty to report first, the person or the company?

The person gaining significant control tells the company first, within 7 days of gaining significant control. Only then does the company's own clock to tell CAC start.

What happens if this record goes stale?

Up-to-date annual returns and PSC information is normally expected before CAC processes other post-incorporation filings. A stale PSC record can hold up a filing that has nothing to do with PSC on its face.

Does a small internal transfer of shares always trigger this?

Only if it results in someone gaining significant control, not for every transfer. This article cannot give a precise threshold; ask a corporate lawyer if you are unsure whether a specific change qualifies.

Sources

Last checked 27 Sep 2026. Fees and rules change; the agency that issues the document has the final word. See our editorial policy.

Keep reading

All articles on cac registration