PPSN Requirement Update: What Irish Company Directors Need to Know
Commencing 23rd April 2023
From 23rd April 2023, when filing Forms A1, B1, B10 and B69, company directors will be required to provide their PPS numbers. The PPS number will be used for identity verification.
What is the reason for this New Filing Requirement ?
On the enactment of the Companies (Corporate Enforcement Authority) Act 2021, it established the Corporate Enforcement Authority in place of the Office of the Director of Corporate Enforcement. This Act also introduced the requirement for all Directors of Irish companies to state their PPS numbers (or equivalent) on certain Companies Registration Office (CRO) forms, namely:
- Incorporating a new company (CRO Form A1).
- Filing an annual return (CRO Form B1).
- Notifying a change of director (CRO Form B10).
- Declaration that a person has ceased to be a director or secretary of a company (CRO Form B69).
Identity Validation
The purpose of the new disclosure requirement is to reduce the risk of identity theft by introducing additional identity validation checks when submitting personal information relating to Directors to the CRO.
Under the new regime, Directors will be identifiable in the online filing platform by their unique PPSN. This is instead of their name, address and date of birth, which can often lead to multiple records if slight variations of a Director’s details are filed with the CRO under different submissions.
A Director’s unique PPSN will be used for identity validation purposes and will not be available on the public register. The CRO will not be able to view the PPSN, which will avoid any opportunity for identity theft. But if a PPSN does not match the PPSN held at the Department of Employment and Social Protection (DEASP), it may result in the submission being rejected.
The CRO will reject submissions where the date of birth and PPSN does not match the information held at the DEASP. Slight variations in Director’s names will be accepted to a certain extent.
To avoid any material discrepancies and delays with filing incorporations, annual returns or changes to company officers, Directors should act now to ensure that the information held at the DEASP is consistent with the information held at the CRO.
Non-resident Directors
For non-resident Directors who do not have a PPSN, they must apply for a ‘Verified Identity Number’, by means of a Form VIF. The form is available here on CORE.
Only one 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.
What next in connection with these New Disclosure Requirements?
If PKF are acting as your filing agent, we will be in contact with you to request your PPSN’s or to assist in applying for a VIF. All Company Directors should take steps to ensure that all PPSNs will be available, and that the Director’s name matches the record held by them in respect of that PPSN.
If you require assistance or advice in relation to any of the above matters, please contact Rachel Curran in our Company Secretarial team. For further information, you can also refer to the CRO website https://www.cro.ie/en-ie/About-CRO/Whats-New/PPSN-FAQ.