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

The CRO has announced that the requirement for PPSN’s disclosure will come into force from the 23rd of April 2023. All Directors will be required to file their Personal Public Service Numbers (PPSNs) with the following forms (and this information will need to be entered each time any of these forms are filed):

• 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.

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 Director’s details (Form B10) and when filing the company’s annual return (Form B1).

The requirement to disclose PPSNs is aimed to help protect against identity theft concerning the set-up of new companies that have used bogus Director details and addresses or individual names without their permission as the PPSN is unique to the individual.

It is also intended to streamline difficulties encountered in obtaining a list of directorships when directors are using variations of their names when filing with the CRO such as ‘Thomas’ and ‘Tom’ or changing their address.

The PPSN will be used for identity verification to ensure that the company director is alive and is a natural person. The PPSN will only be used for validation purposes and will not be available for the public to access on the CRO or sites where such information can be searched. The CRO will also not be able to view the PPSN as it will be hashed and stored securely.

What do I need to do?

We would encourage company officers to begin the process of confirming their Directors’ PPSNs before 23 April 2023, as any delay in this could cause a knock-on effect on the incorporation of companies, registration of Form B10s and 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 and the variation of their name that is registered with the Department of Employment and Social Protection. The Director’s details entered in the CRO must exactly match the name associated with that PPS number in the DEASP’s database.

Non-compliance will constitute a Category 4 offence.

How can Amatino help?

If you require assistance or advice in relation to any of the above matters, please contact your Partner or Accountant in Charge at one of our offices