Skip to main content

Senior managers

When you onboard a limited company, you'll typically declare its directors and any people with significant control (PSCs). Some companies have no PSCs — for example, where shareholding is widely distributed and no single individual holds ≥25% of the shares or voting rights. In those cases, you need to identify one of the company's directors as the senior manager: the individual who has ultimate control of the company.

When you need a senior manager​

You should identify a senior manager when the company you are onboarding has no people with significant control — i.e. nobody holding ≥25% of shares or voting rights, and nobody exercising significant influence or control by other means.

If the company has any PSCs, you don't need to identify a senior manager: the PSCs themselves are the accountable individuals for the company.

The senior manager must be a director of the company you are onboarding.

How to declare a senior manager​

How you declare a senior manager depends on which onboarding model you're using.

You only need to identify one senior manager per company — the regulatory concept asks for a single accountable individual. Only do so when the company has no PSCs; if you later determine that the company does have PSCs after all, declare them instead and remove the senior manager.

Reliance​

In a Reliance onboarding application, declare the nominated director on the subject-association of their related profile, with both director and senior-manager:

{
  "display-name": "JOHNSON, Talia",
  "subject-association": {
    "director": {},
    "senior-manager": {}
  },
  "claims": [
    {
      "claim-type": "individual-identity",
      "given-name": "Talia",
      "surname": "Johnson",
      "date-of-birth": "1985-03-15"
    },
    {
      "claim-type": "individual-residence",
      "building-number": "19",
      "street-name": "Example Street",
      "city": "Test Town",
      "postal-code": "TE1 2ST",
      "country-code": "GB"
    },
    {
      "claim-type": "reliance-verification",
      "reliance-verification-methods": ["manual-biometric", "manual-document"],
      "reliance-verification-standard": "jmlsg"
    }
  ]
}

You provide the same identity, residence, and verification claims as you would for any other director or PSC — see Reliance: Onboard a limited company for the full required-claims table.

Verify and Outsourced​

In Verify and Outsourced onboarding flows, you attach a person-with-significant-control claim directly to the company's legal person, using ownership-percent of "0" and setting the senior-manager? flag to true:

{
  "claim-type": "person-with-significant-control",
  "legal-person-url": "/v0/legal-persons/lp.njk7tIWvQJGPEFIdDmS9yQ",
  "ownership-percent": "0",
  "senior-manager?": true
}
caution

The legal-person-url must reference the same individual legal person you've already attached a director claim for. Don't create a second legal person for the same individual.

See Onboard a limited company (Verify) or Outsourced: Onboard a limited company for the surrounding flow.

Frequently asked questions​

Can a company have both PSCs and a senior manager? No. A senior manager is only required when the company has no PSCs at all. If it has any PSCs, you don't need to identify a senior manager.

Do I need to declare more than one senior manager? No — one director identified as senior manager is sufficient. You should still declare the company's other directors as directors.

The director I want to identify as senior manager already holds shares — is that allowed? Yes, as long as their shareholding is below the PSC threshold (≥25%). If their shareholding is at or above the PSC threshold, they are a PSC — declare them as a PSC instead, and either pick a different director as senior manager or (if any PSCs now exist for the company) skip the senior manager nomination entirely.