CRO Filings Director PPS Number Requirement

Last updated: May 20, 2024

Effective June 11, 2023, Directors of all Irish Limited Companies must provide their PPS Numbers when submitting a number of CRO Filing Forms, such as the company's Annual Return or appointing new Company Directors.

This mandate, originating from the Companies (Corporate Enforcement Authority) Act 2021, has been enacted to address a rising prevalence of identity fraud. On each filing the CRO will cross-reference the Director's submitted name, date of birth, and PPS Number with the data held for that individual on the Department of Social Protection (DSP) database to confirm their identity.

A Scale and a wooden Gavel with scattered file folders on a desk, symbolising the Director PPS Number Requirement.
CRO Filings - Director PPS Number Requirement

What is a PPS Number?

In Ireland, the Personal Public Service (PPS) Number, often referred to as PPSN, serves as a unique identifier for individuals. This number is crucial for identity verification and is extensively used by various government institutions to provide services to Irish residents. Structurally, a PPS Number consists of 7 digits followed by one or two letters, ensuring a distinct identification for each individual.

On What Filings is a PPS Number required?

The Companies (Corporate Enforcement Authority) Act 2021 states that a Director shall include his or her PPS Number in:

  1. An application made under the Act by him or her to incorporate a company.
  2. An Annual Return made under the Act by a company of which he or she is a Director.
  3. A notice of change of Directors or Company Secretaries made under the Act by a company of which he or she is a Director.

NOTE: Failure to comply with this requirement is considered a category 4 offence, and discrepancies in submitted documents may lead to their rejection.

If you Register Your Company through Incorpro, we ensure that all aspects of your company's registration are handled by professionals, including the accurate inclusion of PPS Numbers.

Privacy of Director PPS Numbers in CRO Filings

Concerns about the visibility of Director PPS Numbers on public documents can be allayed. The CRO ensures that once a PPS Number is filed and validated, it is stored in a securely hashed and encrypted format. This advanced security measure makes the numbers inaccessible to third parties, including the CRO members.

NOTE: Director PPS Numbers will never appear on publicly searchable documents.

Rejected Submissions

In the process of verifying Directors' identities, the CRO cross-references each filing against the Department of Social Protection's (DSP) database, comparing the submitted name, date of birth, and PPS number. However, the situation may arise where the particulars that have been previously recorded for the Director with the CRO, are different to those on the Department of Social Protection's (DSP) database, which will result in a rejected submission.

If this is the case, then either the CRO or the Department of Social Protection should be informed by the Director of the correct particulars. Once corrected, the filling can be resubmitted to the CRO.

Directors without an Irish PPS Number

What is a Verified Identity Number (VIN)?

For Directors who do not have an Irish PPS Number, the Companies Registration Office (CRO) has introduced the Verified Identity Number (VIN) as a reliable method for identity verification.

If you're considering our company incorporation services and don't hold an Irish PPS Number, you'll find invaluable insights in our Non-Irish Resident Company Registration Guidance article. This resource is rich with information and detailed steps for starting an Irish Limited Company as a Non-Resident, ensuring a smooth and informed journey into Irish corporate ventures.

How do I apply for a Verified Identity Number (VIN)?

The process of acquiring a VIN involves the submission of a Form VIF - Declaration as to Verification of Identity. This form serves as a formal declaration of the individual's identity, encompassing details such as name, date of birth, nationality, and address.

The Company Director must solemnly declare this information to be correct and true, and have this Declaration verified, witnessed and signed by a Notary Public. Following the completion and signature, the Form VIF must be uploaded to the Companies Registration Office online portal (CORE). Once processed the Verified Identity Number (VIN) is issued and must be used by the Director on future required filings.

If you're looking to Register Your Company through Incorpro, but do not hold an Irish PPS Number, and are not an Irish Resident, a 30-minute Video Consultation with one of our Accountants is required. This consultation ensures that you understand all the implications of opening a company from abroad as a Non-Irish Resident.

VIN number versus RBO number

In the field of Irish company compliance, there has been a significant shift from using the RBO Transaction Number to the newly introduced Verified Identity Number (VIN). Beneficial Owners of Irish companies who didn’t have a PPS Number were required to apply for an RBO Transaction Number to complete their filings.

The RBO Transaction Number was issued on the successful processing of a Form BEN2, on which the new Form VIF - Declaration as to Verification of Identity Form has been modelled. The introduction of the VIN and the VIF Form marks the gradual phasing out of the RBO Transaction Number and the BEN2 Form.

NOTE: Individuals who have been issued an RBO Transaction Number previously can continue to use this number and do not need to reapply for a VIN.

For a deeper understanding of the evolving regulations surrounding Beneficial Owners in Ireland, please explore our comprehensive Register of Beneficial Ownership Guidance article.

Further Guidance and Assistance

Should you have any queries or require assistance with your Accounting and Tax needs, our dedicated team at Incorpro is here to help. Connect with us by calling 01-4429409, or visit our Contact Page for more ways to get in touch. Stay updated and engaged by following our Social Media Pages on Twitter, Facebook, LinkedIn and Instagram.

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