CRO Guidance on B10 Filing Issues

The CRO recently produced a Step-by-step guide to filing a B10 to try and assist presenters to complete the form correctly.

The CRO have now issued another guidance note on the most common reasons for B10 forms to be returned to presenters which is copied below. The CRO have issued the guidance due to the increase in forms not being completed correctly.

See below guidance from CRO.

Returned Submissions

The CRO is currently returning a high proportion of B10s and the main reasons for these returns are:

  1. Pages not signed and/or dated.
  2. Incorrectly dated signature and/or consent pages.
  3. Missing signature and/or consent pages.
  4. Incorrect uploads, for example: signature pages belonging to another CRO submission; including superfluous documentation to incorrect material, such as bank statements, Revenue returns or medical certificates.

Therefore, from 1st October 2024, the CRO will only accept B10 submissions which conform to the following standards:

  1. Signature and/or Consent pages signed by the nominated signatory with an original wet signature.
  2. The submission correctly dated in the format of Day/Month/Year by the nominated signatory.
  3. Dates must also accurately reflect the date that the form was signed. Therefore, back-dating and post-dating is prohibited.
  4. Signatures and dates must be contained within the destinated areas on the Signature and/or Consent pages.
  5. Relevant uploaded material only.

If submissions do not conform to these basic standards they will be returned or possibly rejected. It is the responsibility of the presenter to ensure that submissions are correct. When drafting a submission there are several opportunities to review the submission both for content and to ensure that the correct signature and/or consent pages are uploaded to the appropriate submission. The CRO will return submissions upon request before they are processed. However, if during processing the above criteria are not met then submissions can be rejected. Rejected submissions mean that a new submission is required along with new, correctly signed and dated, signature and/or consent pages.

Additionally, the CRO will continue to monitor the submission of B10s for compliance with Section 149(8) of the Act which states that submissions shall be submitted ‘within the period of 14 days after the date’ of the change that they are recording. At the moment, the compliance rate with this provision is approximately 33 per cent.

If you have any feedback or queries regarding the above please contact the CRO at companyofficers@cro.ie quoting the following text in the subject line ‘Returned and Rejected Submissions’.

NB: The content of this article is provided for information purposes only and does not constitute legal or other advice.

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