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Ireland – Personal Public Service (PPS)

The Companies (Corporate Enforcement Authority) Act 2021 contains a provision requiring the Directors of Irish companies to provide their Personal Public Service (PPS) number on certain documents submitted to the Companies Registration Office (CRO) to allow for verification of a director’s identity.

Application

All Directors of Irish companies will be required to provide their PPS number to the CRO when filing the following forms:

  • Form A1 – Incorporation application;
  • Form B1 – Annual return;
  • Form B10 – Change of company officers or their particulars; and
  • Form B69 – Notice of cessation of company officer where a company has failed to file the notice.

PPS number verification

The CRO will verify the director’s first name, surname, date of birth and PPS number submitted electronically with the data held by the Department of Social Protection.

PPS retention

When the PPS number filed with the CRO has been validated, it will be retained securely in an irreversible hashed/encrypted format and stored securely, and they will never be shared with any third party.

Directors with no PPS number

If a director does not have an Irish PPS number, they must apply for a Verified Identity Number (VIN) by completing a Form VIF (Declaration as to Verification of Identity) and filing it with the CRO.

The Form VIF must state the director’s name, date of birth, nationality, and address, and it must be sworn in the presence of a notary in the director’s home country.

If a director does not have a PPS number but has previously been issued a Register of Beneficial Ownership  number for filings made with the Central Registrar of Beneficial Owners, then the director can use their RBO number as their VIN for CRO filings.

Non-compliance

If any person fails to comply with this new requirement, they shall be guilty of a category four offence resulting in a fine of €5,000.

It will also mean a company cannot complete their filings and could suffer late filing penalties and possible loss of audit exemption.