New Director ID Requirements from the CRO – PPSN and IPN

The new regulation has now come into effect since 11 June 2023 that requires all company directors of Irish registered companies to provide the Companies Registration Office “CRO” with their Personal Public Service Number “PPSN” for certain filings. If the director is non-resident and does not have a PPSN, they will be required to register for an Identified Person Number (IPN).

The regulation - Section 35 of the Companies (Corporate Enforcement Authority) Act 2021 (the “CEA Act”) provides that a director shall include their personal public service number (“PPSN”) in the completion of certain filings at the Companies Registration Office (“CRO”).

Those filings include:

• New company incorporations
• Annual return submissions
• Notice of a change of director or change of company secretary
  
  

Why is the CRO looking for director’s PPS numbers?

Verifying the identity of a director with their PPSN will strengthen trust in the accuracy of the information held by Ireland's Company Registration Office. It can also prevent directors from illegally holding more than 25 Irish directorships and help prevent potential fraudulent companies that attempt to establish unlawfully.

If a person does not provide their PPSN for the completion of the required filings, they will be guilty of a Category 4 offence, as provided for in the Companies Act 2014.

What is the process?

In order to ensure information is valid and secure, the CRO requires that directors include their PPSN on all relevant forms. Upon submission of said form, the data provided will be cross-checked with records from the Department of Social Protection for accuracy – if discrepancies are present in this process, then applications may not go through successfully. Once validation has taken place however, it is important to note that all personal details related to a person's PPSN will be converted into an encrypted format stored securely; allowing future filings to be linked back to individuals already incorporated within the CRO system.

What if I do not have a PPSN?

Non-Irish directors who do not possess a PPSN may rely on Regulation 35 of the CEA Act, which allows for alternative methods to prove their identity. The Registrar will carefully consider two forms of identification in order to guide the decision-making process.

Form VIF – Declaration as to Verification of Identity

Overseas directors must acquire an Identified Person Number (IPN) by submitting the Form VIF - Declaration as to Verification of Identity online. This form requires physical signatures from both director and witness, thus electronic signatures will not be accepted. Scanned copies are acceptable so that all processes can be completed remotely. It is also important to note that any submitted Forms VIF remain confidential and do not become part of the public record.

Each individual is issued just one Identified Person Number (IPN), valid for all future filings with the CRO.

RBO Numbers

The beneficial ownership registration process has been made mandatory by the government since 2019. Overseas individuals must complete a BEN 2 verification form and obtain an RBO number to be able to register, with any director who is given such a number being allowed to use it as their IPN when filing submissions with the CRO.

Will my information be available to the public? 

PPS numbers, RBO numbers and IPNs will not be accessible on the public register.

If you are not registered as the UBO with an Irish company, but you are a director, then you will need to provide the CRO with your PPSN or IPN. This regulation will be introduced on 11 June 2023.

If you need help or want to know more, you can contact a member of our team using the form below: