The RBO released their annual report for the year 2024recently. Below is a brief summary of the report's findings:

• There are a total of 276,891 companies and 703 societies which had filed beneficial ownership information. This is an increase from 258,241 companies and 702 societies in 2023.
• The following is a breakdown of the current beneficial ownership type for active entities with 328,852 individual beneficial ownership/control types recorded for the 276,891 entities which have registered beneficial owners with the RBO to-date: 

Some beneficial owners may be listed twice under different categories

On average each entity registered 1.19 beneficial owner types registered per entity.

• The number of first-time registrations on the RBO has decreased slightly in 2024, with 18,650 companies and 1 society registered compared with 18,797 companies and 4 societies in 2023. The number of companies required to register with the RBO increased by 14,558 in 2024. There were no additional societies required to register with the RBO in 2024.
• The total number of submissions received was 84,314 compared to 89,920 in 2023.
• In July 2023 the RBO stopped receiving applications for BEN2’s and this was replaced with a VIF application to be made to the CRO.
• The overall rejection rate of submissions to the RBO was 21.14%, showing an increase from 18.47% in 2023.
• RBO issued 4,087 Rejection/GDPR letters to data subjects whose personal details were used in RBO submissions which failed the PPSN validation checks, being 32.5% of the overall rejected submissions. The number of Rejection/GDPR letters in 2023 was 5,049, highlighting a definite decrease in rejections due to PPSN errors this year.
• Regulation 25 of Statutory Instrument 110/2019, as amended by SI 308 of 2023, provides for restricted access to the Central Register to be made available to:

• A ‘designated person’ which forms a business relationship with a relevant entity or is taking customer due diligence measures in relation to a relevant entity

• In 2024 a total of 419 Designated Person accounts were set up, a decrease from 1,331 in 2023, and 1183 Sub User accounts were set up. A sub user is an individual account under the main organisational account.
• There is a fee of €2.50 per search for Tier Two access to the Register
• In 2024, 17,451 transactions involving the purchase of Beneficial Ownership reports were completed to a value of €411,370.75. This compares with 18,568 transactions to a value of €400,450.50 in 2023, 61,156 transactions to the value of €405,860.50 in 2022 and 33,501 transactions to a value of €148,040 in 2021.
• The decrease in 2023 was due to access restriction following the decision of the European Court of Justice on the 22nd November 2022.
• In June, the Minister for the Department of Finance signed Statutory Instrument No 308 of 2023, introducing the facility for persons with legitimate interest.
• One application was received in 2024, but it was not granted as the applicant did not satisfy the criteria for access.
• The number of Discrepancy Notices increased in 2024compared with 2023.

• The number of Non-Compliance Notices decreased significantly by 66.75% in 2024 in comparison to 2023.

• The RBO continued its Non-Compliance reminder campaign in 2024 and issued 4,211 pre-deadline reminders to file beneficial ownership information post incorporation to entities in 2024 compared with 5,785 in 2023.
• The RBO also continued its enforcement campaign in 2024, 578 Enforcement letters were issued, and 31 entities were prosecuted.
• 11 entities were convicted
• 20entities pleaded guilty, and the Probation Act was applied.
• Enforcement has continued into 2025
• On 3rd December 2024, the Companies (Corporate Governance, Enforcement and Regulatory Provisions) Act 2024 amended the Companies Act 2014 to provide that the Registrar of Companies may strike off a company for failure to file required information with the Registrar of the RBO.

What to expect in 2025? 

In 2025 the RBO is expected to continue its enforcement campaign against entities that fail or refuse to file on the register.

The Statutory Instrument 639 of Companies (Corporate Governance, Enforcement and Regulatory Provisions) Act 2024 enacted some of the provisions of this act on 3rd December 2024 that relate to the RBO filing. With this, any company who have not filed their beneficial ownership information with the RBO, within either 5 months of this commencement date (03/12/2025) for an existing company, or within 5 months of incorporation for a new company, is at risk of being involuntary struck off the register.

However, the CRO have not yet actively started to involuntary strike off companies for this failure to file. The CRO mentioned in their most recent Stakeholder Meeting, held on 25/06/2025, that these strike offs will commence shortly in the latter half of 2025.

If you require assistance or advice, please contact our Company Secretarial team on 053 91 000 00 or email [email protected]

The contents of this article are meant as a guide only and are not a substitute for professional advice. The authors accept no responsibility for any action taken, or refrained from, as a result of the material contained in this document. Specific advice should be obtained before acting or refraining from acting, in connection with the matters dealt with in this article.