S.150(11) CA2014 permits a company director or secretary who have successfully submitted a Form T1 to not disclose their residential address if they feel that the release of such information may give rise to concerns for their personal safety or security.. Those successful in the process will enter the registered office address of the Company rather than their residential address.
The Form T1 is required per Company and is not a blanket document covering the officer’s address for each company they may be an officer of, extreme care should be taken to ensure the Form T1 is filed per entity, if applicable.
The CRO cannot remove or amend a document from the Register which has already been submitted and in this way Form T1 cannot make retrospective amendments.
The Process
As per CRO procedure, the following is required;
- The request for an exemption is sent to the Registrar in an envelope marked "For the Attention of the Registrar" and is accompanied by the Form T1. As the exemption will apply from the date of the registered T1 – a Form appointing the individual or changing the address of the individual (eg A1 – company incorporation or B10 – change in director details) may also be enclosed with the T1;
- The application requesting an exemption in accordance with section 150(11) must be accompanied by a supporting statement from an officer of the Garda Síochána not below the rank of a Chief Superintendent;
- This statement must contain a request that the usual residential address of a person who is an officer of the company shall not appear on the register kept by the Registrar for reasons of personal safety or security.’
Practical Guide
Individuals who wish to avail of Form T1 should first seek a supporting statement under S.150(11) CA2014 from an officer of the Garda Síochána, not below the rank of Chief Superintendent. This must be a hard copy statement which The Director must make it clear they are requesting this for reasons of personal safety or security and they must be supplied to the Gardai. The accompanying CRO Form Submission Number (SR) must be noted on the Form T1 e.g. Form A1, Form B10 etc. The Completed T1 Form and supporting statement should be sent to CRO and include a Cover Page addressed ‘For the Attention of the Registrar’ to The Companies Registration Office, Bloom House, Gloucester Place Lower, Dublin 1.
If the Registrar is fully satisfied that the officer of the company has fully completed the procedure, the officer will be notified and the exemption is active from the date the Form T1 is registered.
Common Pitfalls
- Information such as PPSN, Date of Birth, other directorships etc is still required to be filed on the relevant forms.
- It is the individual responsibility after registration of Form T1 that their address is not disclosed on any subsequent CRO Forms and they use the registered office address.
- If during the time the T1 is active the Company changes its registered office address the individual should file a B10 to update their address to the new registered office address alongside the B2.
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.
