In the two months since the Register of Beneficial Ownership (“RBO”) opened, a high number of submissions completed by Companies have been rejected. This means the submission is deemed not received and must be fully completed again.
Information relating to the Beneficial Owners forename, surname, date of birth and PPS number are all submitted to the RBO. The Registrar is then required to validate the data entered in the RBO in respect of each beneficial owner, to ensure that the natural person exists, is still alive and to avoid duplication on the Register.
As part of the validation process, the Registrar compares the data filed with the RBO against the data registered with the Department of Employment Affairs and Social Protection (“DEASP”) for that person. The most common reasons for a submission to be rejected are mis-matches between what has been submitted and what the DEASP hold, such as:
- maiden name submitted instead of married name and vice versa;
- middle name used which is not registered with DEASP (middle names are not required in the RBO);
- shortened version or variation of a name, when DEASP has the full/formal version;
- Irish version of a name, when English version is registered with DEASP and vice versa;