Directors:  Requirement for PPS Numbers from 23 April 2023

PUBLISHED: 31st March 2023

From 23 April 2023, all company directors of Irish companies will be required to provide their Personal Public Service (PPS) number to the Companies Registration Office (CRO) when filing the following forms:

• Form A1 – Incorporation Application.
• Form B1 – Annual Return.
• Form B10 – Change of company officers or their particulars.
• Form B69 – Notice of cessation of company officer where a company has failed to file the notice.

If any person fails to comply with the new requirement, he or she shall be guilty of a category four offence.

No PPS Number?

If a director does not have a PPS number but has been issued with an RBO number by the Central Register of Beneficial Ownership, then the director can use their RBO number as their Verified Identity Number (VIN) for CRO filings.

If a director does not have a PPS number or an RBO number, they must apply to the CRO for a VIN which will be issued by the CRO.

Applying for a VIN – Form VIF

Form VIF (Declaration as to Verification of Identity) must state the name, date of birth, nationality and address of the director for whom a VIN is being sought. The director must solemnly declare this information to be correct and true, and have this Declaration verified, witnessed and signed.

Once completed, signed by the director, and witnessed by a Notary Public, the Form VIF is submitted to the CRO and will not be made available to any party or available on the public record.

Will the CRO Store PPS Numbers?

PPS numbers filed with the CRO will be retained securely in an irreversible hashed/encrypted format and stored securely.  The numbers will not be accessible by any member of the CRO or any other party, and will never be shared with any third party.

The CRO will then match the hashed version of the numbers to future filings to avoid duplication of director records.

PPS numbers, RBO numbers and VINs will not be accessible in the public register.

What Next?

Companies and presenters should ensure that all directors have either a PPS number, an RBO number or obtain a new VIN in advance of the next in-scope filing due at the CRO.

To avoid any material discrepancies and delays with filing incorporations, annual returns or changes to company officers, directors should ensure that the information held at the DEASP with the PPS number is consistent with the information held at the CRO. 

If you require assistance or advice in relation to any of the above matters, please contact our experienced Company Secretarial and Corporate Governance team.

Colm Hanley at chanley@lkshields.ie

Michelle Howe at mhowe@lkshields.ie

Patricia Kelly at pkelly@lkshields.ie