New Companies Registration Office requirement for PPS numbers

Upcoming Change

The Companies Registration Office has announced that the new requirement for directors to disclose PPS numbers will commence on 23rd April next. Section 35 of the Companies (Corporate Enforcement Authority) Act 2021 requires all directors to disclose their PPSN when submitting prescribed forms.

PPS numbers will need to be disclosed on Forms A1 (Incorporation Documents), B10 (updating Directors Details) and B1s (Annual Returns).

The PPS numbers will not be publicly available on the CRO website, the information will be encrypted.

Preparation for change

In advance of the implementation of the new requirement we would recommend that directors ensure that their details as held by the Department of Social Protection (DSP) match the details registered with the CRO.

If a director does not hold a PPS number, then there are two options available:

• RBO number

  If a director has registered with the Register of Beneficial Ownership, they will have received an RBO number which can be used on the CRO website.

• Verified Identity Number

  If a director does not have an RBO number or PPSN they can now apply for a VIN number using a VIF form. The forms will be available soon on the CORE system. If this form is completed outside the state, the form must be witnessed in the presence of a notary so overseas directors should allow sufficient time for the process to be completed in advance of upcoming Annual Return Dates.

Implications for Companies

Directors should ensure that the required information is available in advance of upcoming filing dates. Failure to have the requisite information in place may result in submissions being rejected which could lead to delays in submission of returns and ultimately late submission of Annual Returns which would result in the loss of audit exemption, (if applicable) and late filing fees

If you have any queries in relation to same please contact Roberta Flynn.