Ireland: New PPSN Disclosure Requirements for Directors of Irish Companies
From 11th June 2023, directors of Irish companies are required to include their Personal Public Service Number (“PPSN”) when filing certain forms with the Companies Registration Office (“CRO”). If a director does not have a PPSN they can use an existing Register of Beneficial Owners (“RBO”) Filing Number or apply for a Verified Identity Number (“VIN”) and commonly referred to as “VIF”. These provisions were introduced in Section 35 of the Companies (Corporate Enforcement) Act 2021 which inserts a new Section 888A of the Companies Act 2014.
Key changes and requirements
The PPSN, RBO Filing Number or VIN for all directors will be required when filing the following forms with the CRO:
Form A1- Company incorporation (company formation).
Form B1 – Annual return.
Form B10 – Change of director and/or secretary, or in their particulars.
Form B10a – Change in residential address particulars for a director in relation to multiple companies only.
Form B69 – Notification by the individual that he/she has ceased to be a director or secretary.
Failure to provide a PPSN, RBO Filing Number or VIN is a category 4 offence which can carry a fine of up to €5,000 on conviction.
How can we help?
If you have directors of an Irish incorporated company which do not have a PPSN or an existing RBO Filing Number, we can assist you in obtaining a VIN to ensure your directors and company can comply with this new obligation.
It is particularly important that you have either a PPSN, RBO Filing Number or VIN in place before your next Annual Return Date as failure to comply will result in delays to filing the Annual Return which would result in late filing penalties, loss of audit exemption for two years, if applicable, and possible further enforcement action.
For our GEMS clients, it should be noted that GEMS now provides the ability to capture PPSNs/IPN (Identified Person Number issued by the Registrar upon application for VIN) on the Person record. The B1 and B10 forms in GEMS have also been updated to capture a director's ID type and number as per these requirements.
Contact:
Please contact your dedicated Computershare Relationship Manager or send an email to globalentityservices@computershare.com for more information about how Computershare may assist you in responding to these new requirements.
This notice is provided by Computershare for general informational purposes only and is not intended and should not be construed as legal, regulatory, financial or tax advice. Computershare is not licensed or authorized to practice law in any jurisdictions and hence does not provide any legal advice and it does not hold itself out as doing so. Neither Computershare nor any of its affiliates or contributors accept any responsibility or liability for the quality, accuracy or completeness of any information contained in this notice. It is important that you seek independent professional advice relating to the subject matter of this notice before relying on it.