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Identity Verification Obligations for Directors Now in Force

AUTHORs: Kieran Trant Services: International Business DATE: 23/06/2023

New Companies Registration Office identity verification obligations for directors came into effect on 11 June 2023, following a short delay to resolve IT issues. In terms of legislative underpinning to this new requirement, the Minister of State for Trade Promotion, Digital and Company Regulation signed a Commencement Order, eventually giving effect to section 35 of the Companies (Corporate Enforcement Authority) Act 2021.

As outlined in a previous update, under the new system, certain prescribed company filings, including annual returns, must contain a Personal Public Service number (“PPSN”) or an Identified Person Number (“IPN”) for all the company's directors. Some potential difficulties with the new regime have been flagged; for example:

  • where an outgoing director who, on appointment, had not been required to produce a PPSN/IPN, is unwilling to supply verification details; or
  • an outgoing director lives outside Ireland and is unwilling to go before a notary public to obtain an IPN to allow the company to comply with the new measures.

The new forms regulations with the prescribed forms have been published.