Directors Requirement to Supply a PPS Number on CRO Filings CRO FILINGS - Director PPS Number Requirement

What is a PPS Number?

A Personal Public Service (PPS) number, which is sometimes called a PPSN, is a unique reference number that is used in Ireland for identity verification purposes. A number of government institutions rely on the PPS Number for the provisions of services to Irish residents. A PPS Number is always 7 numbers followed by either one or 2 letters.

On What Filings is a PPS Number required?

The Companies (Corporate Enforcement Authority) Act 2021 states 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, and
3. A notice of change of directors or secretaries made under the act by a company of which he or she is a director.

If any person fails to comply with this, he or she shall be guilty of a category 4 offence. Discrepancies on submitted documents may lead to rejected submissions

Will Director PPS Numbers be visible on publicly available CRO documents?

No. Once the PPS number filed with the CRO has been validated it will be stored in an irreversible hashed/encrypted format rendering them inaccessible to any third party and even CRO members. Director PPS Numbers will never appear on publicly searchable documents.

Rejected Submissions

As noted above, 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 the director's identity. The situation may arise however where the particulars that have been previously recorded for the director with the CRO are different to those on the Department of Social Protection Database. This will result in a rejected submission. If this is the case then either the CRO or 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)?

The Verified Identity Number (VIN) has been established by the Companies Registration Office as the method for verifying an individual's identity when a director does not possess an Irish PPS Number. If you are interested in using our company incorporation services, and you do not currently hold and Irish PPS Number, you may also be interested in reading our note on Starting an Irish Limited Company as a Non-Resident.

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

A VIN is issued by the CRO on successful submission of a Form VIF - Declaration as to Verification of Identity. You can view the document here. The VIF serves as a declaration confirming the identity of the individual. It includes the person's name, birth date, nationality, and address. The company director is required to solemnly affirm the accuracy of this information and have the declaration verified, observed, and signed. Upon completion and signature by the declarant (company director) and witness (e.g., Notary Public), 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 are interested in using our Company Incorporation Services and do not hold an Irish PPS Number please contact us at cosec@incorpro.ie.

VIN number versus RBO number

Beneficial Owners of Irish companies, who did not hold a PPS Number, had previously to apply for an RBO Transaction Number in order to complete the filing. 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. You can read more about the Register of Beneficial Owners in our note here. The introduction of the VIN and Declaration as to Verification of Identity Form will see the RBO number, and BEN2 Form, phased out. Individuals who have been issued an RBO Transaction Number previously can continue to use this number however and do not need to reapply for a VIN.