PPSN Disclosure for Directors commencing 23rd APRIL, 2023

New PPSN Requirement

The Companies Registration Office (CRO) have announced that the new requirement for directors to supply their PPSN’s (Personal Public Service Numbers) when making certain filings will commence on April 23^rd, 2023.

These filings include:

• Incorporating a new company (Form A1)
• Notifying a change of director (Form B10, B69)
• Filing the yearly Annual Return (Form B1)

 What Should Directors Do To Prepare?

If the director has a PPSN, then they should verify their details with the DEASP. The CRO will crosscheck a director’s PPSN, name and date of birth with the information held by the Department of Employment Affairs and Social Protection.

The CRO will accept an 80% match to account for slight discrepancies in forenames (ex. ‘Sue’ instead of ‘Susan’ or ‘Marc’ instead of ‘Mark’) however, if there is a discrepancy with any part of the other information, the CRO will reject the filing.

• Contact Details- Client Identity Services can be reached at 0818 927 999 (or +353 71 967 2616 if calling from abroad).

 What If The Director Does Not Have A PPSN?

If the director does not have a PPSN and is resident in Ireland, they should apply for a PPSN as soon as possible. An online PPS Number application can be made at mywelfare.ie. Proof of address, ID and evidence of why a PPSN is needed will be required.

If the director is not resident in Ireland but has been issued with an RBO number previously (from filing with the Register of Beneficial Owners), this can be used in place of a PPSN. Otherwise, a VIF Form will need to be filed to obtain a Verification of Identity Number.

 Is The Director’s Information Safe?

PPSNs Will Not Be Available on the Public Register. The CRO will only store a hashed version of the PPSN so that they cannot be seen even internally. This will avoid the opportunity for identity theft.

 What Are The Consequences For Not Preparing?

In the case of a company formation, rejection by the CRO will cause a delay in the company’s incorporation.

In the case of a change of Directors, rejection by the CRO would impede a range of issues including bank account operation.

Late filing of the Annual Return will result in late fees of €100 + €3 per day until the filing is completed. More importantly, the company will lose audit exemption for the next two sets of financials filed with their Annual Returns.

 How can CFI help?

Although filing agents will be unable to check the DEASP details of a director due to GDPR constraints, CFI can assist with VIF Number applications.

Our staff are extremely knowledgeable in regard to formations, the filing of Annual Returns and registering any changes in directorships or Director information. We would be more than happy to assist in any aspect of these filings along with the submission of a Director’s PPSN.

For assistance with any aspect of this topic, why not contact Sue Jesper at [email protected] or Jeena Cardenas at [email protected] for advice on preparing for this new requirement?

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