New PPSN disclosure requirement for Company Directors
Effective from 11th June 2023 (originally 23rd April 2023), directors are required to include their Personal Public Service Number (“PPSN”) when filing certain forms with Companies Registration Office (forms A1, B1, B10, B10a and B69)
The PPS number will be used for identity verification to ensure that the company director is alive and is a natural person. This requirement aims to mitigate the risk of identity theft and enhance the accuracy and integrity of information held by the CRO.
Directors who do not have a PPSN have two options: they can use an existing RBO number or apply for an Identified Person Number ("IPN"). These provisions were introduced in Section 35 of the Companies (Corporate Enforcement) Act 2021 which inserts a new Section 888A of the Companies Act 2014.
These new requirements may cause delays in registering documents if the PPSN details are incorrect, or a director is trying to track down their RBO number or must apply for a IPN. The following will be the main types of transactions that may be affected:
· Incorporations
· Changing Directors Details
· Filing Annual Returns
As all the directors must include their PPSN in the annual return this may be one of the biggest challenges for companies, particularly companies with the imposition of late filing fees and loss of audit exemption for late annual returns.
The CRO will verify the director’s first name, surname, date of birth and PPSN submitted electronically with the data held by Department of Social Protection. If the information does not match the CRO form will be rejected.
If a director does not have a PPSN then:
A director may use an RBO number; or
Apply for an Identified Person Number (“IPN”)
The Companies Registration Office (“CRO”) have published a helpful FAQ page on their website that details the new requirements and the common questions that directors may have.
The Corporate Enforcement Authority (“CEA”) have also issued a guidance note on the PPSN requirements.
Please contact us if you have any questions in relation to this new requirement or need any support.