After a short delay with implementation, the new PPS number disclosure requirement will commence from 11 June 2023.

All company directors of Irish companies will be required to provide their Personal Public Service (PPS) number to the Companies Registration Office (CRO) when filing the following forms:

  • Form A1: Incorporation application.
  • Form B1: Annual return.
  • Form B10: Change of company officers or their particulars.
  • Form B69: Notice of cessation of company officer where a company has failed to file the notice.

Any person that fails to comply with the new requirement shall be guilty of a category 4 offence.

No PPS Number?

If a director does not have a PPS number but has been issued with an RBO number by the Central Register of Beneficial Ownership (CRBO), then the director can use their RBO number as their Verified Identity Number (VIN) for CRO filings.

If a director does not have a PPS number or an RBO number, they must apply to the CRO for a VIN which will be issued by the CRO.

Applying for a VIN – Form VIF

Form VIF (Declaration as to Verification of Identity) must state the name, date of birth, nationality and address of the director for whom a VIN is being sought. The director must solemnly declare this information to be correct and true, and have this Declaration verified, witnessed and signed.

PPS numbers, RBO numbers and VINs will not be accessible in the public register.

Mandatory Online Filings from 11 June 2023

A range of CRO forms will become mandatory online filings through the CORE portal from 11 June 2023:

  • G1 B4: Special Resolution to increase authorised share capital
  • G2 B4: Ordinary Resolution to increase authorised share capital
  • B5: Allotment of shares
  • B7: Variation of share capital
  • B69: Notice of cessation of company officer where a company has failed to file the notice
  • B77: Authorisation/revocation of electronic filing agent
  • Branch F2: Alterations in the memorandum/articles of external company
  • Branch F3: Change in directors/secretary/persons who represent an external company/authorised persons/persons responsible for compliance with regulations
  • Branch F7: Return of accounts
  • Branch F12 and F13: Registration of a branch
  • Branch F14: Notification of closure of branch/ liquidation of company/ insolvency proceedings/ appointment of liquidator

Paper forms received by post at the CRO after 11 June 2023 will be returned for submission online.

Proposed Enhancements to the Companies Act 2014

A public consultation on proposals to enhance the Companies Act 2014 was launched by the Department of Enterprise, Trade and Employment on 8 May 2023.

The proposed changes include:

  • Amending the audit exemption regime for small and micro companies to remove the automatic loss of audit exemption for late filing of annual returns and establishing a two-step gradual procedure where failure to file an annual for a second time within a five-year period would result in loss of audit exemption.
  • Providing companies and societies with the option to hold fully virtual AGMs and general meetings on a permanent basis.
  • Delivering on the commitment in the Programme for Government in relation to the regulation of receivers.
  • Extending certain reporting obligations to examiners, interim examiners and process advisors.
  • Enhancing certain powers for the Corporate Enforcement Authority, the Auditing and Accounting Supervisory Authority and the Companies Registration Office to strengthen the State’s capability to meet the challenges faced in investigating and prosecuting alleged breaches of company law.

Anyone wishing to make a submission in relation to these proposals should do so by 9 June 2023.