New statutory requirements in the Republic of Ireland mean that, from 11 June 2023, the directors of Irish companies will be required to provide their Personal Public Service Number (PPSN) when the company files certain forms with the Registrar.
Individuals who do not have a PPS number will need to apply for a Verified Identity Number by means of Form VIF. When an individual is outside the Republic of Ireland, they can sign the VIF form in the presence of a Notary Public.
Below is a more detailed description of what has changed and how our notaries can assist:
In line with the global tendency towards more stringent checks on company ownership and control, Ireland is introducing a new requirement for the directors of Irish companies to state their Personal Public Service Number (or an accepted equivalent, as explained below) when their company submits certain forms to the Companies Registration Office.
In particular, this will be applicable to the submission of Form A1 (incorporation of a new company), Form B1 (annual return) and Forms B10 and B69 (used to notify changes of directors).
A failure to do this can result in a ‘Category 4 offence’ (that is, a summary offence punishable by the imposition of a fine).
The PPSNs, which will be used for identity verification, have long been used in Ireland for access to certain public services, social welfare, etc. The PPSN is a unique reference number formed of 7 numeric digits and 2 letters. Unlike passport numbers, which in many countries change upon renewal of the passport, PPSNs are permanent and, therefore, provide an unchanged link to the person’s identity.
Since individuals who are directors of Irish entities but do not reside in Ireland may not have been issued with an Irish PPSN, an alternative system of verification of identity has been designed for this purpose. Individuals who do not have an Irish PPSN will need to complete a Verification of Identity Form (VIF), which will result in the allocation of an Identified Person Number (IPN). This IPN can then be quoted in the company’s filings with the registrar instead of the PPSN.
When an individual is based outside the Republic of Ireland, the Verification of Identity Form (VIF) will need to be signed in the presence of a Notary Public. The notary witnesses the signing of the form and confirms the signatory’s identity in a manner that is acceptable to the Irish Companies Registration Office.
There is an exception which applies to individuals who have previously completed and filed a BEN 2 Form with the Companies Registration Office. The BEN 2 Form is used to verify the identity of individuals who are beneficial owners of a relevant entity, so that their details can be entered into the Register of Beneficial Ownership. It results in the allocation of an RBO Number. This RBO Number can also be used (instead of a PPSN or an IPN) for the submissions of the above-mentioned forms covered by the new regulations. BEN 2 forms require notarisation in a similar manner to the VIF.
If you are (or plan to become) a director of an Irish entity and you do not have an Irish IPN or RBO number, our notaries can assist with the witnessing of your VIF form in London and surrounding areas. We also continue to offer the service of notarising BEN 2 Forms for those who need to register as beneficial owners of relevant entities.
Get in touch with our team for more information.