Get ready for new requirement to file director PPSN in CRO

From 11 June 2023, directors will be required to provide a Personal Public Service Number (PPSN) or other identity verification when filing certain forms in the Companies Registration Office (CRO).

Forms affected

Form A1 – for incorporation of a new company

Form B1 – annual return

Form B10 – for the appointment or resignation of a director, or change of their details

Form B69 – notice by a director of cessation of office where a company has failed to file a form B10

Details required

For Irish resident directors the PPSN must be supplied.  In the case of non-resident directors, if an RBO Number has been issued for the purpose of filings with the Central Register of Beneficial Ownership of Companies and Industrial & Provident Societies (the RBO) where the director did not hold a PPSN, this RBO number will automatically be reclassified as an "Identified Person Number" (IPN) by the CRO and it will not be necessary to obtain a separate identity number in such cases.

If a director does not hold either a PPSN or an RBO number, it will be necessary for such director to apply to the CRO for an IPN by means of a Form VIF - Declaration as to Verification of Identity (VIF). The CRO have confirmed that only one VIF is required in respect of each director. Once this has been processed successfully and an IPN is issued by the CRO, that number can be used for making future filings for that person.

Declaration as to Verification of Identity

The VIF will contain the name, date of birth, nationality and address of the person. The company director must solemnly declare this information to be correct and true and have this Declaration verified, witnessed, and signed.

Once completed and signed by the Declarant (company director) and Witness (eg Notary Public), the Form VIF should be uploaded in the CORE Portal.  As the VIF is a Declaration verifying a person's identity, digital or electronic signatures cannot be accepted on the VIF.

Act now!

Any relevant entity that fails to file a PPS number with the CRO where such a number has been assigned to a director, and/or submits a VIF application where a PPS number exists for the director, will have committed an offence. Companies and directors should start to take steps to ensure that all directors have either a PPSN or IPN, to ensure no delays in filing the relevant forms.