What is changing?
The CRO has announced that the requirement for PPSN’s disclosure will come into force from the 23rd of April 2023.
All Directors will be required to file their Personal Public Service Numbers (PPSNs) 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.
This information will need to be entered each time any of the prescribed forms are filed by an entity.
Why do I need to disclose my PPSN?
Section 35 of The Companies Corporate Enforcement Act (2021) requires Directors to file their PPSNs with the CRO when incorporating a new company (Form A1), being appointed as a Director of an existing company, updating Director's details (Form B10) and when filing the company’s annual return (Form B1).
The requirement to disclose PPSNs is aimed to help protect against identity theft concerning the set-up of new companies that have used bogus Director details and addresses or individual names without their permission as the PPSN is unique to the individual.
It is also intended to streamline difficulties encountered in obtaining a list of directorships when directors are using variations of their names when filing with the CRO such as ‘Thomas’ and ‘Tom’ or changing their address.
The PPSN will be used for identity verification to ensure that the company director is alive and is a natural person.
Non-compliance will constitute a Category 4 offence.
What do I need to do now?
We would encourage all filing agents and company officers to begin the process of confirming the Directors PPSNs before 23 April 2023, as any delay in this could cause a knock-on effect on the incorporation of companies, registration of Form B10s and annual return filings which could result in late filing fees and the loss of audit exemption for companies.
Company Directors should ensure that they are aware of their PPSN and the variation of their name that is registered with the Department of Employment and Social Protection (DEASP).In order for there to be a match between the two sets of data, the forename and surname entered in the CRO must exactly match the name associated with that PPS number in the DEASP’s database.
The Director's Date of Birth must also match with DEASP records.
What if I do not have PPSN?
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 VIF number on the CRO CORE System.
If a Director does not have a PPSN or RBO transaction number, there is an alternative process where the Director must apply for a Verification Identity Number by means of a Form VIF – Declaration as to Verification of Identity. This form will be available on CORE.
Note: it is an offence for any relevant entity that fails to file a PPS number with the CRO where such a number has been assigned to a director, and/or submits a VIF application where a PPS number exists for the director.
What is a Form VIF – Declaration as to Verification of Identity?
The Form VIF will be used for the purpose of verification of a person’s identity where the Director does not have an Irish PPS number assigned to them or an RBO Transaction number. 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.
The Form VIF consists of 3 parts:
Part 1 requires the following details of the person to be verified:
- First name
- Last name/Surname
- Date of Birth
- Residential Address
Part 2 is a Statutory Declaration where the declaration is being made in the State.
Part 3 is a Declaration being made outside the State and must be signed by a Notary Public
Once completed and signed by the Declarant and Witness, the Form VIF should be uploaded to the CORE Portal.
Digital or electronic signatures will not be accepted on the VIF.
Will my PPSN be on the public register?
PPSNs will only be used for validation purposes and will not be available for the public to access on the CRO or sites where such information can be searched.
The CRO will also not be able to view the PPSN as it will be hashed and stored securely.
The VIF Form is also retained securely by the CRO and will not be available to view or searchable.
What do I need to file with the Companies Registration Office?
If all the Directors have valid PPSNs or VIF/BEN2 numbers, there will not be any additional forms required to be filed with the CRO.
The PPSNs/VIF 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.
How can we help?
The OmniPro Corporate Consultants team will release blogs and webinars on this topic as information is released from the CRO.
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.