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Soon, when filing Forms A1, B1, B10 and B69, company directors will be required to provide their PPS numbers. The PPS number will be used for identity verification to ensure that the company director is alive and is a natural person. For Frequently Asked Questions on this, please see below.
Your Personal Public Service (PPS) number, which is sometimes called a PPSN, 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.
You have a PPS number if:
PPS numbers are also issued to non-resident persons who have dealings with certain Irish Government organisations, including the Revenue Commissioners.
PPS numbers are printed on the following documents:
If you do not know your PPS number, please contact your Intreo Centre or local Social Welfare Branch Office and staff there can find your number for you.
You need your PPS number when you are using certain public services. There are only certain services that are allowed to ask for your PPS number. The Companies Registration Office is authorised to use the PPS number.
The Companies (Corporate Enforcement Authority) Act 2021 states a director shall include his or her personal public service number in:
If any person fails to comply with this, he or she shall be guilty of a category 4 offence.
When the mandatory PPS number data filed with the CRO has been validated, a PPS number will be retained securely in an irreversible hashed/encrypted format and stored securely. It will not be accessible by any member of the CRO or any other party, and it will never be shared with any third party.
The reason for retaining a hashed version of the PPSNs is to allow CRO to match future filings to existing individuals on the register with certainty and to avoid duplication.
Hashing is an encryption function to protect data on the register in the event of a data breach. This technique will apply a complex mathematical function to the PPS number, to produce a longer unique number that bears no resemblance to the number hidden. With hashing, the CRO will never be able to reverse the newly generated number back into a PPS number again.
Yes, it is required each time any of the prescribed forms are filed.
The CRO verifies the name, date of birth and PPS number submitted in forms by comparing them, via an electronic interface, with data held on the PPS number database of the Department of Social Protection (DSP).
In order for there to be a match between the two sets of data, the forename and surname entered in the CRO must exactly match the name associated with that PPS number in the DSP’s database.
The Registrar reserves the right to reject any submission where the name entered on the CRO does not match the name as registered for that PPS number with the DSP.
This process allows CRO to verify the identity of each beneficial owner, prove that they are a natural person and minimise the possibility of duplicate entries.
If you do not have an Irish PPS number, then you must apply for an Verified Identity Number, by means of a Form VIF - Declaration as to Verification of Identity.
Only one VIF is required in respect of each director. Once this has been processed successfully and an Identified Person Number (IPN) is issued by the Registrar, that number can be used for making future filings for that person.
Any relevant entity that fails to file a PPS number with the CRO where such a number has been assigned to a director, and/or submits a VIF application where a PPS number exists for the director, will have committed an offence.
The Form VIF is the method that the Registrar has determined will be used for the purpose of verification of a person’s identity where the director does not have an Irish PPS number assigned to them.
The VIF is a Declaration as to Verification of Identity. The VIF contains the name, date of birth, nationality and address of the person. The company director must solemnly declare this information to be correct and true and have this Declaration verified, witnessed and signed.
Once completed and signed by the Declarant (company director) and Witness (eg Notary Public), the Form VIF should be uploaded in the CORE Portal.
As the VIF is a Declaration verifying a person's identity, digital or electronic signatures cannot be accepted on the VIF.
If you have already completed a BEN2 and have been issued with an RBO number, this number can be used as the Identified Person Number (IPN) on the CRO CORE System.
The form is available here on CORE.
The Form VIF consists of 3 parts:
Part 1 requires the following details of the person to be verified:
Part 2 is a Statutory Declaration where the declaration is being made in the State.
Part 3 is a Declaration being made outside the State and must be signed by a Notary Public
On both Part 2 and Part 3 of the VIF Form, a declaration must be made as to how the identity of the person has been established.
A number will issue upon verification of the details contained on the VIF Form by the CRO, and will be emailed to the presenter and person themselves.
The VIF Form is retained securely by the CRO and will not be available to view by anyone.
The form is only viewed and processed by the CRO for the purposes of verifying the details entered and for the issuing of the Identified Person Number (IPN). It is not searchable or accessible to any Third Party.
No, you do not, if it is used for the same company director as identified on the Form VIF.
However, a number must be applied for each individual person who is a director/beneficial owner but for whom a PPS number has not been issued.
If you have any further queries in relation to this matter, please contact us by e-mailing the CRO at: firstname.lastname@example.org
Courtesy from https://www.cro.ie/en-ie/About-CRO/Whats-New/PPSN-FAQ
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