On Sunday 11th June, the CORE platform will be introducing the requirement for Personal Public Service Numbers (PPSNs)or Identified Person Numbers(IPNs) for Director(s)on Forms A1, B10, B10A, B69 and B1. For more information on this see below.
As well as this there will be new mandatory online filings as part of the CRO’s expansion of mandatory electronic filing with the Digital Tools Directive which came in on 1st August 2021.
The following Formswill all be moved to online forms only;
- Form G1 B4: Increase Authorised share capital and Resolution
- Form G2 B4: Increase Authorised share capital and Resolution
- Form B5: Return of Allotments
- Form B7: Notice of Consolidation, Division, Conversion
- Form B69: Cessation of Director/Secretary
- Form B77: Notice of Authorisation/Revocation of an Electronic Filing Agent (EFA)
- Form F12: Registration of an External Company - Branch (EEA)
- Form F13: Registration of an external Company - Branch (NON EEA)
- Form F2: Alterations in the memorandum/articles of external company
- Form F3: Change in directors/secretary/persons who represent an external company/authorised persons/persons responsible for compliance with regulations
- Form F7: Return of accounting documents of an external company
- Form F14: Notification of closure of branch/ liquidation of company/ insolvency proceedings/ appointment of liquidator
If the manual equivalent is sent to CRO after 11th June 2023 it will be returned and will need to be submitted online.
It is important now for agents to avoid any unnecessary administrative burden to contact any clients whom may have not returned any of the above forms and such forms should then be directed to CRO ahead of 11th June. If a manual Form is received after 11th June, the agent will need to refile the Form on CORE and reissue the Signature Page to the client for signing. Agents should now also familiarise themselves with CORE for such forms.
Refresher on PPSN for Directors
Section 35 of The Companies Corporate Enforcement Act (2021) which has not yet commenced will require Directors to file their PPSNs or IPN with the CRO when incorporating a new company, being appointed as a Director of an existing company, updating Director's details and when filing the companies annual return.
All Directors will be required to file their PPSNs or IPNs with the following forms;
- Form A1- Company incorporation,
- Form B1 – Annual return,
- Form B10 – Change of director and, or in their particulars,
- Form B10a – Change in Director address/name filed in relation to multiple companies, and
- Form B69 - Notification by the individual that he/she has ceased to be a director or secretary.
For Directors who do not have PPSN there are two options available;
If you have already completed a BEN2 Form with RBO and have been issued with an RBO number, this number can be used as the Identified Person Numbers (IPNs) on the CRO CORE System.
The Form VIF available on CORE will be used for the purpose of verification of a person’s identity, similar to that of the RBO BEN2 Form, the company director must solemnly declare this information to be correct and true and have this Declaration verified, witnessed and signed. Once the VIF is certified and ready to be uploaded you will be directed to insert the individuals details followed by uploading the VIF and submitting this to the CRO. Once this has been processed successfully and an IPN is issued by the Registrar, that number can be used for making future filings for that person. A new IPN will not be required to be completed again.
What if the name I use is different to the details on my PPSN?
The CRO has indicated there is to be a match between the forename and surname entered in the CRO and what would be reflected in the DEASP’s database.
There will be additional fields on the CORE forms under the name section detailed as “Name registered with Department of Social Protection for PPSN purposes (if different)”.
If the Director(s) name is different, such as Pat is registered on CRO but Patrick with DEASP you will be able to enter such details into that field and that will then be matched against the DEASP record and the entity will not be required to submit a B10 to reflect this. The CRO has not indicated how closely names will need to match in order for this to be accepted. If you have any concerns regarding a name the CRO has a dedicated email address available under the PPSN FAQ section of their website which you can refer to.
What if I do not submit my PPSN/IPN?
On and after the commencement of section 35 of the Companies (Corporate Enforcement Authority) Act 2021, any person who, without just cause, fails to comply shall be guilty of a category 4 offence.
For example with Form B1, if PPSN is not included the submission cannot be completed and be registered with CRO and the Company would likely enter involuntary strike-off and be struck off the Register.
What are the next steps?
The PPSNs/IPNs will not be required to be filed until the next filing is due with the CRO, i.e. a Company Formation, Change of Directors Details or Appointment and Filing the Annual Return for your company.
However, if you are concerned with any upcoming deadline for any of the above forms you may submit the VIF now through CORE.
What do I need to do now?
We encourage all Directors and filing agents to review their company information and reconfirm the company officers’ details to ensure that they are correct and exactly match what is on record with the Department of Social Protection (DSP). The Registrar reserves the right to reject any submission where the name entered on the CRO does not match the name as registered for that PPS number with the DSP.
How can we help?
If you require assistance or advice in relation to any of the above matters, please contact our team on 053 91 000 00 or email [email protected]
Please note this information is accurate as of the time of publication.