Director Obligations to Disclose PPS Number
Have you disclosed your PPS number to the CRO?
From 23 April 2023, all Company Directors of Irish companies have a statutory filing obligation to disclose their Personal Public Service (PPS) Number to the Companies Registration Office (CRO).
PPS Numbers are to be disclosed when filing the following forms:
- Form A1 – Incorporation Application.
- Form B1 – Annual Return.
- Form B10 – Change of company officers or their particulars.
- Form B69 – Notice of cessation of company officer where a company has failed to file the notice.
What is a PPS Number?
Your PPS Number is a unique reference number that helps you access social welfare benefits, public services and information in Ireland.
A PPS Number is always 7 numbers followed by either one or 2 letters. It is sometimes called a PPSN.
You have a PPS Number if:
- You were born in Ireland in or after 1971
- You started work in Ireland after 1979
- You are getting a social welfare payment
- You are taking part in the Drugs Payment Scheme
Note: The CRO plan to redact the PPS Number from all forms, by placing hashes over the numbers and letter(s). No publicly accessible form or document will display your PPS number.
What if I do not have a PPS Number?
If a director does not have a PPS number but has been issued with an RBO number by the Central Register of Beneficial Ownership, then the director can use their RBO number as their Verified Identity Number (VIN) for CRO filings.
If a director does not have a PPS Number or an RBO Number, they must apply to the CRO for a VIN which will be issued by the CRO.
Consequences for non-compliance
This new requirement is being introduced to help with the identification of directors and to prevent fraud.
A director that fails to comply with the regulations commits an offence under Section 35 “888A (2)” of the Companies (Corporate Enforcement Authority) Act 2021 and shall be guilty of a category four offence.
What should you do next?
We strongly advise all clients who have not already provided us with their PPS number, RBO number or obtained a new VIN to do so, as a matter of urgency, to avoid any material discrepancies and delays with the next in-scope filings due at the CRO.
Directors should further ensure that the information held at the DEASP with the PPS number is consistent with the information held at the CRO.
Please email our Corporate Compliance Team if you require any assistance.
