Public consultation for changes to the Companies Act 2014, the Co-operative Societies Bill and the Registration of Limited Partnerships and Business Names Bill is open until 5 pm on 19 December 2025.

The Department of Enterprise, Tourism and Employment is seeking opinions regarding access to Directors' and Secretaries' addresses. This comes on the heels of the Company Law Review Group (CLRG) report from September 2025, named “Report on the Review of the provisions pertaining to the disclosure of an officer’s residential addresses having regard to company transparency requirements and GDPR” which outlined six recommendations.

1. The Group recommends legislative change to preclude the default public availability without qualification, in the operation of the 2014 Act, of Relevant Officers’ usual residential addresses as contained in the Register and submitted as prescribed to the CRO. This recommendation is contingent on there being appropriate timely mechanisms for the CRO, members of the public, relevant authorities and other interested parties (such as creditors) to effectively engage with and identify Relevant Officers.
2. The Group recommends legislative change to require that, in addition to their residential address, Relevant Officers provide a contact address, which could be their usual residential address, the registered office of the company, or another address as prescribed. This contact address must be located in the State. The contact address will be the only address that appears to the public on the Register kept by the company and that is made publicly available without restriction by the CRO.
3. The Group recommends legislative change as above to also preclude the default public availability without qualification of residential addresses in the case of companies required to register pursuant to Part 21 of the 2014 Act (external companies).
4. The Group recommends that the legislative change proposed in the first recommendation should provide for the timely permitted disclosure of the usual residential address. The Group views that categories to whom disclosure is permitted should include competent authorities and other actors who require the usual residential address for the purposes of law enforcement, regulatory compliance and judicial proceedings. The Review Group recommends that the question of serving proceedings be clarified in the implementing legislation.
5. The Group recommends that, therefore, in a context where the usual residential address is no longer publicly available without restriction, the 2015 Regulations should be repealed and appropriate legislative change made to s150 of the 2014 Act. Relevant Officers, who successfully made a T1 application and currently use the company’s registered office address, should provide a usual residential address to the Registrar and failure to do so should be an offence.
6. The Group recommends that the legislative change does not have retrospective effect and applies from the date of the coming into effect of the statutory changes.

Currently, under the Companies Act 2014, unless a Director or Secretary successfully applies for Form T1 non-disclosure of residential addressCompany Officer they are required to submit the residential address on Form A1, B10, Register of Directors, Register of Secretaries, etc.

It is intended to amend the Companies Act 2014 to provide that a company’s officer may at any time provide to the company a “contact address”, located in the State, in addition to their “usual residential address” already supplied, for the purposes of access by the public. This new ‘contact address’ will be visible on CRO record and the internal Register of the Company, while the ‘usual residential address’ will still be retained by CRO with limited access to relevant entities or by court order.

However, these changes will not have a retrospective effect so the “usual residential address” of relevant officers will continue to be available on previous filings with the CRO.

Also, those whom currently hold T1 may be required to submit their ‘usual residential address’ as well as the ‘contact address’ if the legislation comes into force.

This is a welcome change for Directors and Secretaries and their concerns around security, safety and protection; however, it is disappointing to see that at this stage the amendment does not have a retrospective application.

If you would like to have your opinion heard on the topic, access to the document can be found here https://enterprise.gov.ie/en/consultations/public-consultation-on-proposed-changes-to-the-companies-act-2014-and-related-legislation.html

In meantime if you need assistance with Form T1, please contact the Team on https://omnipro.ie/contact-us/

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.