New Requirement
The Companies (Corporate Enforcement Authority) Act 2021 was signed into law on 22 December 2021 (“the Act”). The Act contains a provision requiring all directors of Irish companies to provide their personal public service number (PPSN) when filing an annual return (Form B1), incorporating a new company (Form A1) or notifying the Companies Registration Office (the CRO) of a change of director (Form B10). By requiring a PPSN as a unique identifier, there is a reduced risk of identity theft and will avoid multiple or differing records being held by the CRO for the same person.This new requirement is due to be implemented by the CRO in the latter part of Q1, 2023 giving the presenters of the above forms and companies sufficient time to ensure that the relevant details are available when required.
Verification of Identity
An important thing to note is that the details on any form must match the details linked to the PPSN which are held by the Department of Employment Affairs and Social Protection (DEASP). The date of birth must be an exact match, however, the CRO will accept slight name spelling variations. The CRO will not be able to view the PPSN when the form is submitted and will store a hashed version of the number providing reassurance that there will be no opportunity for identity theft when sharing the PPSN with the CRO.
Non-resident Directors
Where non-resident directors do not hold a PPSN, it is envisioned that there will be an alternative process for obtaining a unique identifying number, similar to that which was in place when making submissions to the Register of Beneficial Ownership (RBO).
Preparation
It is advisable to ensure that companies have access to the relevant PPSNs for all directors and that the directors ensure that the details held by the CRO and the DEASP match. This will ensure that no delays to filings are experienced as a result of conflicting information.
