The Companies Registration Office (CRO) has confirmed that from 23 April 2023 directors of Irish companies will be required to provide their personal public service number (PPSN) or a verified identity number (VIN) when making the following filings:
- Form A1 - Company Incorporation
- Form B1 - Annual return
- Form B10 – Notice of change of director or their particulars
- Form B69 – Notice by a director that they have ceased to be a director where company has not filed a B10.
The purpose of this new requirement isto assist the CRO with verification of the identity of directors, by comparing their name, date of birth and PPSN with the data held on the PPSN database of the Department of Social Protection.
The legislative basis for this new requirement is section 888A of the Companies Act 2014, which was inserted by section 35 of the Companies (Corporate Enforcement Authority) Act 2021.
Where a director has a PPSN they will be required to provide it with the CRO filings outlined above.
Directors Without a PPSN
Where a director does not have a PPSN, but has been issued with an RBO number in connection with filings with the Central Register of Beneficial Ownership (RBO), the RBO number can be included as the VIN for the relevant CRO filings.
Where a director does not have a PPSN or an RBO number they must apply to the CRO for a VIN by means of a Form VIF (Declaration as to Verification of Identity). The Form VIF is not yet available.
Access to PPSN
A director's PPSN or VIN will not be displayed on the CRO's public register. The CRO has confirmed that PPSNs will be retained securely and will not be accessible by any member of the CRO or by any third party.
Action Points
- Company secretaries and other presenters should ensure that PPSN/ RBO numbers for all directors can be made available in connection with any of the relevant filings.
- Directors should check that their personal details (name, date of birth) are consistent with those on record with the Department of Social Protection.
- Directors without a PPSN or RBO number should take steps to obtain a VIN once the Form VIF is made available.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.