Update on the Register of Beneficial Ownership and Personal Public Service Numbers

PUBLISHED: 29th July 2019

After a short delay, The Register of Beneficial Ownership of Companies and Industrial and Provident Societies (“RBO”) is now open with Companies being required to complete their initial disclosures by 22 November, 2019.

Update – PPSN

As previously mentioned in our various updates, a Personal Public Service Number (“PPSN”) is required to be disclosed by all individuals who have obtained such a number.

Clarity has now been provided in respect to beneficial owners who do not have a PPSN. It has been determined under Regulation 21(2)(b), SI 110/2019, that a Form BEN2 - Declaration as to Verification of Identity - will be the method to be used to verify the person’s identity. 

What is the form BEN2

The BEN2 is a Declaration as to Verification of Identity. The BEN2 contains the name, date of birth, nationality and address of the beneficial owner. The beneficial owner must solemnly declare this information to be correct and true and have this Declaration verified, witnessed and signed.

The Form BEN2 will consist of 3 parts:

• Part 1 requires the following details of the beneficial owner/person to be verified:
  • Forename
  • Surname
  • Date of Birth
  • Nationality
  • 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.

On both Part 2 and Part 3 of the Form BEN2, a declaration must be made as to how the identity of the person has been established.

Once completed and signed by the Declarant (beneficial owner) and Witness (eg Notary Public), the BEN2 will be uploaded in the RBO Portal.

Only one BEN2 will be required in respect of each beneficial owner and once this has been processed successfully and an RBO Transaction Number issued by the Registrar, that Number can be used for making future beneficial ownership filings for that person.

The Form BEN2 is not available from the RBO as of yet but we expect same will be available shortly.

Next Steps

We have been advising a great deal of our company secretarial clients on their obligations and will also be completing the various filings at the RBO for our clients.  If you do have any questions in meeting your statutory obligations, please do not hesitate to contact our company secretarial team.