From 11 June 2023, when making certain submissions to the Companies Registration Office (CRO), company directors will be required to provide their Personal Public Service Numbers (PPSNs) with their filings.
The PPS number will be used for identity verification, with the aim of improving the integrity of company information held by the CRO and to reduce the risk of identity theft.
Company directors will need to provide their PPSN when:
- Incorporating a new company (CRO Form A1)
- Filing an annual return (CRO Form B1)
- Notifying a change of director and/or secretary, or in their particulars (CRO Form B10)
- Notifying that an individual has ceased to be a director or secretary (CRO Form B69)
Section 35 of The Companies Corporate Enforcement Act (2021) requires Directors to file their PPSNs with the CRO when incorporating a new company (Form A1), being appointed as a Director of an existing company, updating Directors details (Form B10) and when filing the company’s annual return (Form B1).
Non-compliance will constitute a Category 4 offence, which is a summary offence only, punishable by the imposition of a Class A fine. A “Class A fine” is a fine within the meaning of the Fines Act 2010 (i.e. a fine not exceeding €5,000).
Only certain services are authorised to ask for a PPSN, the Companies Registration Office is one of these authorised services.
When the mandatory PPS number data filed with the CRO has been validated, a PPS number will be retained securely in an irreversible hashed / encrypted format and stored securely. It will not be accessible by any member of the CRO or any other party, and it will never be shared with any third party.
The reason for retaining a hashed version of the PPSNs is to allow CRO to match future filings to existing individuals on the register with certainty and to avoid duplication.
Hashing is an encryption function to protect data on the register in the event of a data breach. This technique will apply a complex mathematical function to the PPS number, to produce a longer unique number that bears no resemblance to the number hidden. With hashing, the CRO will never be able to reverse the newly generated number back into a PPS number again.
No publicly accessible document or form will display your PPSN.
This change will bring many benefits to all stakeholders, including:
- The reduced risk of identity theft
- The CRO will contribute to the effort of ‘Designated Persons’ in combatting money laundering and terrorist financing, with the company director identification and verification
- The option to use digital signature in the form of a ROS certificate where a PPS number has been obtained
- Greater transparency across government bodies
Ensure all of the directors of your company have a PPSN, RBO transaction number or IPN.
Limited companies should confirm with all directors that they hold a PPSN, Registered Beneficial Owner (RBO) transaction number or Identified Person Number (IPN).
If an individual has already completed a BEN2 Form with RBO and have been issued with an RBO number, this can be used as the IPN with the CRO.
If a director does not hold a PPSN or a RBO transaction number, they should apply to the CRO to have an IPN issued through a ‘Form VIF’ (Declaration as to Verification of Identity). The Form VIF must state the name, date of birth, nationality and address of the director for whom the IPN is required. The VIF Declaration must be signed by the Director and if the declaration is made within the State it must be witnessed by a solicitor, if the declaration is made outside the State it must be witnessed before a Notary Public. Digital signatures will not be accepted.
Limited companies should review the information held by the CRO to confirm the details are correct or if there are any inconsistencies between this data and the details under the PPSN held by the Department Social Protection (DSP). The Directors name and date of birth with the CRO must exactly match the name associated with the PPSN in the DSP’s database.
The Registrar reserves the right to reject any submission where the name entered on the CRO does not match the name as registered for that PPS number with the DSP.
To avoid the risk of late filing fees and / or the loss of audit exemption, please contact a member of our Corporate Compliance team to confirm your PPSN as soon as possible, before the deadline of 11 June 2023.
If you have any questions on this matter, please get in touch.
Corporate Compliance Team
Richard Windrum, Director
This article is for guidance purposes only. It does not constitute legal or professional advice. No liability is accepted by UHY Farrelly Dawe White Limited or UHY FDW Corporate Compliance Limited for any action taken in reliance on the information set out in this article. Professional or legal advice should be obtained before taking or refraining from any action as a result of this article. Any and all information is subject to change.
Update: This article has been updated to reflect the announcement from CRO on the delay in PPSN requirements, issued 20 April 2023 https://www.cro.ie/en-ie/About-CRO/Latest-News/delay-in-ppsn-requirement
Update: This article has been updated to reflect the announcement of the new deadline date from CRO, issued in May 2023.