With effect from the 23rd April 2023, the Companies Registration Office (CRO) will require a PPS number for each director on the following forms: –
• Form A1 (Incorporating a new Company)
• Form B1 (Annual Return)
• Form B10 (Changes of Directors and or their particulars)
• Form B69 (Individual notification of a person ceasing to be a director)
This PPSN will be required each time such forms are filed.
It is worth noting that Directors names and dates of birth must exactly match that listed on the Department of Social Protection’s database.
If any person fails to comply with this obligation, they shall be guilty of a category 4 offence.
If you do not have an Irish PPS number, then you must apply for a Verified Identity Number, by means of a ‘Form VIF-Declaration’. The ‘Form VIF’ is the method that the Registrar of Companies has determined will be used for the purpose of verification of a person’s identity where the director does not have an Irish PPS number. The VIF contains the name, date of birth, nationality and address of the person to be verified. Once completed the company director must solemnly declare this information to be correct and true and have this Declaration verified, witnessed and signed. Once completed and signed by the Declarant (company director) and Witness (e.g. Notary Public), the Form VIF should be then be uploaded through the CRO’s CORE Portal.
Currently, a copy of the BEN2/VIF form can be accessed from the CRO through the following link: –https://www.cro.ie/en-ie/Registration/Beneficial-Ownership/RBO-BEN-2-Form
(Note: currently the CRO are working on producing a separate VIF form, which should become available in due course)
Only one BEN2/VIF is required in respect of each director. Once this has been processed successfully and a Verified Identity Number is issued by the Registrar, that number can be used for making future filings for that person, if you have already completed a BEN2/VIF form and have been issued with an RBO number, this number can be used as the VIF number on the CRO CORE System.
For those companies for whom we currently act for in the capacity of company secretarial e-filing agents we would request that all such clients should send us on the details of their directors PPS numbers prior to the 23rd April 2023 to ensure that submissions are not refused by the CRO resulting in late filings. The PPS numbers can either be sent to us by email to cosec@fmb.ie or via our secure uploading facility on our website (https://fmb.ie/client-login-page/)
Should you require any further information or need to speak to a member of staff please do not hesitate to contact us.
