The Companies (Corporate Enforcement Authority) Act 2021 requires all directors of Irish companies to input their Personal Public Service Number (PPSN) on specific CRO forms.
As many directors of Irish companies are non-resident in Ireland and do not have a PPSN the CRO, to prevent administrative difficulties, introduced an Identified Person Number (IPN) to be used instead of a PPSN. A Verification of Identity for CRO and RBO form (VIF) must be completed for an IPN.
This new process will protect the identity of directors and avoid identity theft.
The number when used will only be visible to the form presenter and not to the public and will be stored by the CRO in a hashed frormat.
Directors who do not have a PPSN/RBO/IPN can expect some delays when filing forms A1, B1, B10, and B69 with the CRO.
Before company incorporation or being appointed, a director must have a PPSN or IPN.
When filing the annual return all directors must either hold a PPSN/IPN or a RBO number. The director information must substantially match the Department of Social Protection (DSP) and if not the return will be returned to the presenter for clarification with DSP. However we have had returns rejected due to a missing apostrophe or a middle initial not being included.
A PPSN/IPN or an RBO number is also required to amend the details of a current director.
When a PPSN is provided to the CRO it will be checked with the DSP. If a match is found the filing is processed. If an IPN or RBO number is provided the CRO will check it against their records to ensure a match before they allow the filing.
You should check that you have either a PPSN or IPN and that the PPSN information held by the DPS matches that with the CRO. We suggest for there to be a match the forenames, surname and any middle initials must exactly match.
The CRO said it would accept the return if the information substantially matched the data held by DSP. It seems to be more like exact match.
Failing to check could result in CRO annual return deadlines being missed which means fines and loss of audit exemption for two years.