Since the beginning of 2024, the CRO have been closely examining B10 submissions, whether they have been submitted on time and in particular, focusing on the main reasons they might be returned.

So far this year, the CRO have returned approximately 17,000 B10 submissions, which represents 35% of the total submissions. Most of these returns were due to the issues listed below.

- Signature and/or consent pages not signed or dated

- The wrong signature page uploaded

- A Signature page but no consent page

- A consent page but no signature page

- Secretary appointment and no resignation [or vice versa]

- Dates written illegibly.

- Forms dated at a future date.

- B10 effective dates which pre-date a previously registered submission which an outgoing officer has certified

As we can appreciate, checking submissions for correct completion is very time-consuming for the CRO, especially during busy periods when annual leave needs to be considered. The CRO aim to have a short turnaround time of 3-5 working days from receipt of submission to processing/registration, particularly as we approach peak filing later in the year, however this may not always be the case due to increased filing, and as stated above, staff annual leave leading to a lack of resources.

To help reduce these occurrences, the CRO have provided some guidelines on how to complete a B10 signature and/or consent page properly: 

• B10 forms should be submitted within 14 days of the proposed changes.
• Once a B10 is REGISTERED, it cannot be returned or amended. Please ensure the EFFECTIVE date of the submission is correct before you submit. The onus falls on the officer certifying the signature page to ensure the details on the form are correct.
• When there is an appointment, the submission must be completed with a signed and dated signature and consent page. The two pages must be scanned together as a single PDF file.
• B10 forms MUST be signed with an original wet signature in the designated box on the statutory signature and consent pages. DOCUSIGN or digitally generated signatures are not accepted.
• Dates SHOULD be in the DAY/MONTH/YEAR format and should be written clearly. There should be no ambiguity over the date, It must be written clearly. Too many submissions have dates type signed with very small font size to the point they are illegible. B10 signature and consent pages MUST be dated on/after the effective date but they also cannot be dated into the future.
• The officers chosen to certify submissions, they should also date the submission. The date should be a true and accurate reflection of the date the submission was certified.
• Signature and Consent Pages should be scanned to portrait alignment, at 100% siize and the full version of both pages MUST be fully viewable. There can NOT be a cut and paste portion of either page uploaded. They are statutory forms on the public register.
• All scans must be CLEAR and legible. They should not be blurred or missing portions of the pages.
• Please ensure there is no other document scanned. The only pages required are the statutory signature and consent page. We do NOT require a copy of the B10 to be scanned. Please also ensure no third party documents are accidently scanned to the PDF file to be Uploaded.
• Before Uploading the PDF file, please ensure the Submission number at the top right corner of the signature page matches the submission number as per your CORE workspace. If there is any appointments on the submission, please ensure both the SIGNATURE and CONSENT pages are in the PDF to be uploaded.
• When appointing a new secretary, the current/outgoing secretary must also be resigned, be it on the same B10 form, or else on two separate B10 forms with the same effective date.
• When you select the T1 box, for Non-disclosure of residential address of a company officer, the correct address to enter is the registered office address of the company. This should only be selected if the officer is submitting the manual T1 form along with the supporting letter from An Garda Siochana.

• The Section 137 Bond box should only be ticked if the changes on the B10 being drafted result in the company being left with no EEA resident director and therefore require a bond.

The CRO are also highlighting the importance of filing the Form B10 on time, whether it is appointing or resigning a director/secretary or updating details relating to the current company officer, as outlined by the Companies Act 2014 below:

Section 149(8) provides the company shall, within the period of 14 days after the date of the happening of—

(a) any change among its directors or in its secretary or assistant or deputy secretary; or

(b) any change in any of the particulars contained in the register,

send to the Registrar a notification in the prescribed form of the change and of the date on which it occurred.

If you would like to discuss any of the above with a member of our team please contact a member of staff at 0539100000.

The contents of this article are meant as a guide only and are not a substitute for professional advice. The author/s 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.