Directors required to provide PPSN when filing certain CRO Forms
New Identity Verification Mechanism for Directors
From the 23 April 2023 directors of Irish companies will need to provide their Personal Public Service Number (‘PPSN’) or a Verified Identity number (VIN) when filing certain forms with the Company Registration Office (‘CRO’).
CRO Forms that now Require Identity Verification
The Companies Act 2014 has been amended by s 35 of the Companies (Corporate Enforcement Authority) Act 2021. From the effective date (23rd April 2023) directors of Irish companies will need to provide details of their PPSN or VIN when filing any of the following forms:
- Form A1 – incorporating a company,
- Form B1 –filing an annual return,
- Form B10 –notice of change of a director or secretary,
- Form B69 –notice of cessation of a director or secretary.
Although a director’s PPSN will be used for identity validation purposes, it will not appear on the summary page of any CRO filing, nor will it be publicly available. Non-compliance with this new filing requirement will result in the director being guilty of a Category 4 Offence under the Companies Act 2014.
What if I don’t have a PPSN?
Persons without a PPSN must apply for a Verified Identity Number (VIN) using a Form VIF (a declaration as to Verification of Identity). Once completed, the Companies Registrar will issue a VIN to the director which can be used by the director when making filings going forward. If a VIF has been completed and the director has already been issued with a reference number from the Register of Beneficial Ownership of Companies and Industrial and Provident Societies (‘RBO’), the RBO number can be used as the VIN number, until the PPSN issues.
PPSN Storage
The CRO will store personal data securely. The PPSN’s held by the CRO in an irreversibly encrypted form using hashing. The CRO will retain the encrypted version of the PPSN so that it can align future filings with persons already on the register.
Conclusion
Directors should be aware that before the end of the month they must provide their PPSN or provide other information for identity verification when filing certain forms in the CRO. This new regime should enhance the overall accuracy of information held on the companies register.
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