This new requirement will be implemented by the Companies Registration Office (CRO) from 23rd April 2023.
The Companies (Corporate Enforcement Authority) Act 2021 contains a provision requiring all Directors of Irish companies to provide their personal public service number (PPSN), when:
- incorporating a new company (CRO Form A1),
- filing an annual return (CRO Form B1); or
- notifying a change of director (CRO Forms B10, B10A and B69).
This new requirement will be implemented by the Companies Registration Office (CRO) from 23rd April 2023. Any of the above forms submitted without PPSNs (awaiting signature and payment) before 23rd April 2023 must be signed and paid before 23rd April 2023 as they will be rejected on or after 23rd April 2023.
It is our understanding that the Directors details submitted to the CRO will need to be an exact match with the details held by the Department of Employment and Social Protection (DEASP) and the CRO may reject forms that contain a minor mismatch of information. The CRO will reject any of the above-mentioned forms where the date of birth on the form does not match the date of birth linked to that PPSN on the DEASP database.
A mismatch in the information may cause the company’s filing with the Companies Registration Office to be rejected and it may take some time to resolve the mismatch. If the company is unable to file its annual return on time due to a mismatch of information the company may lose its entitlement to claim audit exemption for two financial years and may incur substantial late filing fees imposed by the Companies Registration Office.
To avoid the CRO rejecting submissions made to it, all Directors are encouraged to review the information (including PPSN, name, address and date of birth) held by the Department of Employment Affairs and Social Protection for them. This can be found on your Public Services Card or correspondence you may have recently received from the Department in relation to, child benefit, state pension or illness benefit. In the situation where the Department has not corresponded with you recently please contact the Department of Employment Affairs and Social Protection to verify the records which are held for you. Any out-dated information identified should be updated to ensure that the CRO record and DEASP record are matched.
In the case of a director who does not have a PPSN, and does not have an identification number issued by the Register of Beneficial Ownership the Director will be required to apply to the CRO for a Verified Identification Number. Directors that have been allocated an identification number by the RBO can use that number for CRO filings.
The Companies Registration Office are developing their information systems to redact PPSNs from all forms submitted to ensure that PPSNs are not disclosed to the public.
Should you have any queries on the above, please do not hesitate to contact us.
Regards
Denis Healy
Senior Manager - Quintas
