Directors will be required to disclose their PPSN with effect from 23 April 2023.
As of 23 April 2023, a new requirement will be introduced that all directors of Irish companies must disclose their personal public service number (PPSN) when completing certain statutory filings with the Companies Registration Office (CRO). This provision is part of the Companies (Corporate Enforcement Authority) Act 2021, which aims to increase transparency and prevent fraud in the Irish business landscape.
What does this mean for companies?
All directors will need to disclose their PPSN when incorporating a new company, filing an Annual Return, notifying a change of director, or declaring cessation of director or secretary. This information will be used to verify the directors identity and link them to the companies they are involved with, providing greater transparency.
All directors will be required to disclose their PPSN when:
- Incorporating a new company (Statutory Form A1);
- Filing an Annual Return (Statutory Form B1);
- Notifying a change of director (Statutory Form B10); and
- Declaration of cessation of director or secretary (Statutory Form B69).
This information will be disclosed on the above-mentioned statutory forms. However, the PPSN will not be visible to the public.
What if a director does not have a PPSN?
For non-Irish resident directors who do not have a PPSN, the directors will be required to apply for a Verified Identity Number (“VIF”), by means of a Form VIF - Declaration as to Verification of Identity.
The VIF contains the name, date of birth, nationality, and address of the person.
The VIF must be completed and signed by the Declarant and witnessed by a Notary Public. Once signed the form must be filed online on CORE.
If a director already has an RBO number, this can be used as the VIF number.
What is next?
To ensure a smooth transition, companies and agents should start collating the PPSNs for directors to ensure that they have the required information ready for submission. It is advised that companies review the information on file for its directors and ensure that this information matches the information held by the Department of Employment Affairs and Social Protection (DEASP).
If a directors information does not match the DEASP records, the submission will be rejected by the CRO. It is important to note that there will be some allowances for minor discrepancies with a spelling of a name.
If you require further assistance or advice on what this means for you as a director or for your company, please feel free to reach out to the experienced Corporate Governance team in BDO Dublin at cosec@bdo.ie