The CRO have released the below blog post on the PPSN disclose requirements for directors and some of the issues presenters may have when filing certain CRO Forms.
The requirement for company directors to provide Personal Public Service Numbers (PPSN) came into force on 11 June 2023. After three months, the system has bedded in and the CRO has been able to identify some particular issues that presenters and directors may wish to address.
To take a typical day (26/09/2023), for example, there were a total of 1799 forms requiring a PPSN received by the CRO. Of these, 145 (8%) were returned by the online system. A further 372 were subject to offline scrutiny by CRO staff where a decision can be made on a close match of a director’s name.
The majority of returns were due to a fundamental failure to match a director’s name, PPSN and date of birth held by the Department of Social Protection (DSP). The CRO advises presenters to ensure that directors verify the information they are supplying before submitting forms to the CRO. In particular, it is important that the date of birth supplied to the CRO matches exactly with the date of birth on the DSP database.
It is also important to remember that a director may use a different name on the CRO register than that held by the DSP. For example, James O’Reilly may be registered with the CRO but the DSP may have Seamus O’Reilly on record. It is important therefore that as a first step, the director’s data on CORE should be checked to ensure that it is correct. The online CORE form has a field titled “Name registered with Department of Social Protection for PPSN purposes (if different)” and this should be filled in to avoid any delay in registering the form.
Where a director has been issued with a PPSN it is compulsory to use that PPSN when submitting a form to the CRO. Where a director does not have a PPSN but does have a Register of Beneficial Owners (RBO) number, then the RBO number can be used. If a director does not have either a PPSN or an RBO number the director can apply for an Identified Person Number (IPN) using the VIF form. The IPN is a number issued by the CRO to directors/beneficial owners who do not have a PPSN or an RBO number and can be used to file with either RBO or CRO. For further information on PPSN, RBO or IPN please see the CRO website PPSN – FAQ (cro.ie).
If presenters have queries not dealt with on the CRO website these can be emailed to crodirectorid@enterprise.gov.ie.
As we approach the peak filing period the CRO recommends that presenters ensure that they have the full details in relation to the directors of companies well in advance of the company’s filing date. If it is necessary to apply for an IPN then that should be done as soon as possible in order to ensure that the IPN is issued in good time for the filing deadline. While the CRO will endeavour to deal with all IPN applications promptly, processing times will depend on the volumes of applications received so the earlier the application is made the better.
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