Section 35 of the Companies (Corporate Enforcement Authority) Act 2021 has now been signed into law and will take effect on 11th June 2023. This means that certain filings to the CRO after this date will require a PPS number for company directors.

The filings which will require the submission of a PPS number are incorporation (A1), annual return  (B1), and change of director or secretary details (B10 and B69).

The changes will allow the Companies Registration Office to verify the identity of company directors and avoid duplication where name variations or differing addresses have been submitted in respect of individuals. It will allow for more efficient detection of fraudulent activity.

This will impact any individuals who might wrongly hold more than 25 active directorships under name variations. These people will now need to rectify the situation.

It will also impact non-Irish company officers, who are likely not to possess a PPS Number. A PPS number is an individual number assigned as an identifier for access to public services. Non-Irish company directors may have a PPS number if they have previously had dealings with the Revenue Commissioners in Ireland.

The majority of non-Irish directors will not have a PPS number, so will require an Identified Person Number or (IPN) for their dealings with the CRO. They will need to complete a Form VIF- Declaration of Identity. Once this VIF has been processed by the CRO, a IPN will issue and may be used by the individual for all future CRO filings.

The VIF is contains the name, date of birth, nationality, and address of the individual. It must be declared as true by the director and verified, witnessed by a notary and signed in wet ink. It must then be uploaded to the CORE Portal.

Conveniently, if an individual has already completed a BEN2 form for the Register of Beneficial Ownership, this number can be used as the IPN.

The above is provided for information purposes and is not intended as legal advice. We, at Fitzsimons Redmond LLP, would be happy to talk to you about your company secretarial needs. Please contact us on 01-676 3257.

By Lisa Quinn O’Flaherty

Partner at Fitzsimons Redmond LLP