New CRO Requirements- Personal Public Service Numbers (PPSNs) for Directors

Directors of incorporated companies will soon have to provide their personal tax numbers when completing electronic filings with the Companies Registration Office (CRO) for incorporations, annual returns and change of directors.

What's Changing?

The CRO has announced that the requirement for PPSN’s disclosure will come into effect from the 23rd of April 2023.

All Directors will be required to file their Personal Public Service Numbers (PPSNs) with the following forms;

Form A1- Company incorporation,
Form B1 – Annual return,
Form B10 – Change of director and, or in their particulars,
Form B10a – Change in Director address/name filed in relation to multiple companies, and
Form B69 - Notification by the individual that he/she has ceased to be a director or secretary.

This information will need to be entered each time any of the prescribed forms are filed by an entity.

Why must a Director now disclose their PPSN?

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). It is important to note that non-compliance will constitute a Category 4 offence.

What do I need to do now?

The CRO has advised that all filing agents and company officers should now begin the process of confirming the Directors PPSNs before 23 April 2023. Any delay associated with this could cause knock-on effects for the incorporation of companies, registration of Form B10s and with annual return filings which could result in late filing fees and the loss of audit exemption for companies.

Company Directors should ensure that they are aware of their PPSN that is registered with the Department of Employment and Social Protection (DEASP). The Directors name and date of birth must exactly match the name associated with that PPSN in the DEASP’s database.

What if a Director does not have a PPSN?

If a Director does not have a PPSN or RBO transaction number, there is an alternative process where the Director must apply for a Verification Identity Number by means of a Form VIF – Declaration as to Verification of Identity. This form will be available on CORE.

What do I need to file with the Companies Registration Office?

If all the Directors have valid PPSN’s or VIF/BEN2 numbers, there will not be any additional forms required to be filed with the CRO until the next filing is due with the CRO.