The CRO requires company directors from June 11 2023 to provide a PPS number for identity verification to ensure that the company director is a natural person.
If a director has already completed a BEN2 and has been issued with an RBO number, this number can be used.
Either number is required when filing Form A1 to incorporate a limited company; Form B1 to file the Annual Return; Form B10 to notify changes to the company’s director or secretary or to their details (e.g. change of residential address) and Form B69 to declare that a person has ceased to be a director or secretary of a company which has failed to send notification of the said cessation.
A Personal Public Service (PPS) number, which is sometimes called a PPSN, is a unique reference number of 7 numbers followed by either one or 2 letters.
The CRO verifies the name, date of birth and PPS number submitted in forms by comparing them with data held on the PPS number database of the Department of Social Protection (DSP).
In order for there to be a match between the two sets of data, the forename and surname entered in the CRO must exactly match the name associated with that PPS number in the DSP’s database.
When the mandatory PPS number data filed with the CRO has been validated, the PPS number will be retained securely in an irreversible hashed/encrypted format and stored securely. It will not be accessible by any member of the CRO or any other party and it will never be shared with any third party.
If a director does not have a PPSN, then an application must be filed with the CRO for a Verified Identity Number (VIF).
The VIF is a Declaration as to Verification of Identity. The VIF contains the name, date of birth, nationality and address of the person. The company director must solemnly declare this information to be correct and true and have this Declaration verified, witnessed and signed.
Only one VIF is required in respect of each director.
A Identified Person Number (IPN) will issue upon verification of the details contained on the VIF Form by the CRO and will be emailed to the address listed on the VIF form.
Once the IPN is issued by the Registrar, that number can be used for making future filings for that director.
Any relevant entity that fails to file a PPS number with the CRO where such a number has been assigned to a director will have committed an offence.
Any relevant entity that submits a VIF application where a PPS number exists for that director will have committed an offence.
The VIF Form is retained securely by the CRO and will not be available to view by anyone.
A number must be applied for each individual person who is a director/beneficial owner but for whom a PPS number has not been issued.
If a person now uses a different form of their name, they complete the section “Name registered with Department of Social Protection for PPSN purposes (if different)”.
This is the name (if completed) that will get matched against the DSP database.
In the case of a person who does not have a PPS number and is registering their first Irish company, they have to complete the VIF Form prior to submitting the A1 Form to incorporate their company.