Submitting a director PPSN is now a mandatory step when filing certain forms with the Companies Registration Office (CRO). This guide explains exactly what is required and how directors can comply.
Understanding the Director PPSN Requirement
On 7 June 2023, the commencement of Section 35 of the Companies (Corporate Enforcement Authority) Act 2021 via S.I. 292/2023 introduced a new compliance obligation: company directors must now submit their Personal Public Service Numbers (PPSNs) when filing certain forms with the Companies Registration Office (CRO) via the CORE platform.
Applicable Forms
Directors must include their PPSNs when filing the following forms:
- Form A1 – Company Incorporation
- Form B1 – Annual Return
- Form B10 – Change of Director and/or Director Details
- Form B10a – Multiple Changes in Director Name or Address
- Form B69 – Director or Secretary Resignation Notification
Each time one of these forms is filed, the PPSN must be submitted and will be verified against Department of Social Protection (DSP) records.
Why Is This Required?
The key purposes behind the introduction of PPSN filing are:
- To combat fraudulent directorships using false identities
- To prevent identity theft
- To eliminate duplicate records caused by name/address variations
- To ensure consistency in director identification across companies
Legal Basis
The legal requirement stems from Section 888A of the Companies Act 2014 (as inserted by the 2021 Act), which mandates that:
“A director shall include his or her PPSN (or other Registrar-approved identity details) in applications to incorporate a company, in annual returns, and in notices of change of directors or secretaries.”
Failure to comply without just cause constitutes a Category 4 offence, punishable by a Class A fine (up to €5,000).
What is a PPSN?
A Personal Public Service Number (PPSN) is a unique reference number used in Ireland for accessing public services and benefits. You are likely to have a PPSN if:
- You were born in Ireland after 1971
- You started working in Ireland post-1979
- You are receiving a social welfare benefit
- You are using public health schemes like the Drugs Payment Scheme
What If a Director Doesn’t Have a PPSN?
There are two alternative processes:
1. Use an RBO (BEN2) Transaction Number
If a director previously filed a BEN2 form with the RBO and received a transaction number, this can be used in place of a PPSN.
2. Apply for an IPN via Form VIF
If no PPSN or BEN2 number exists, the director must submit a Form VIF to apply for an Identified Person Number (IPN). This form must be:
- Completed with the director’s full details
- Witnessed and signed (either in Ireland or abroad)
- Uploaded via the CORE portal
Note: It is an offence to file a VIF where a PPSN already exists.
Form VIF Overview
The Form VIF contains three parts:
- Part 1 – Personal information (name, DOB, nationality, address)
- Part 2 – Statutory declaration within Ireland
- Part 3 – Declaration outside the State (requires a Notary Public)
Once processed, an IPN is issued and emailed to the CORE account user for future filings.
How the CRO Verifies PPSNs
Submitted name, PPSN, and date of birth are verified electronically against DSP records. Names must match exactly. Variants used with Revenue or banks do not suffice.
The CRO allows for “Alternate First and Last Name” fields to reflect the name held by the DSP without changing public-facing records.
Name Matching Challenges
Discrepancies can prevent filings. Examples include:
| Registered Name | VIF Entry | CORE Entry | Outcome |
| William Hennessy | William James Hennessy | William Hennessy | Approved |
| Sharon Dempsey | Sharon Mary Dempsey | Sharon Dempsey | Approved |
| Martin Jim O’Reilly | Martin O’Reilly | Martin Jim O’Reilly | Likely returned |
Always ensure VIF names match DSP records or adjust CORE entries accordingly.
Special Cases – Using the Form VIFa
Where a director has resigned or passed away, and the PPSN cannot be obtained, the CRO provides a temporary workaround: Form VIFa.
Use Case Example:
- A company is listed for strike-off
- An annual return is outstanding from a year when a now-unreachable director was in office
- The company cannot retrieve their PPSN
In this case, Form VIFa allows temporary filing access via a short-lived IPN issued by the CRO.
Form VIFa includes:
- Director and company details
- Details of former directorship and resignation
- Declaration under Irish law (Part B) or foreign law (Part C)
Key Points to Remember
- PPSNs/IPNs are never publicly visible or searchable on CRO systems
- Digital/e-signatures are not accepted for Form VIF/VIFa
- The CRO validates all details directly with DSP – not Revenue or other agencies
- Do not file a VIF if a PPSN already exists – this is an offence
Consequences of Non-Compliance
Failure to provide the PPSN or file a valid VIF/IPN will:
- Result in filing rejections (e.g., B1s, A1s, B10s)
- Lead to late annual return penalties
- Potentially trigger strike-off proceedings
- Attract fines of up to €5,000 (Category 4 Offence)
Need Assistance?
If you’re having issues filing with a PPSN or IPN, you can contact the CRO’s dedicated support email:
directorid@cro.ie
Subject Line Template:
Form Type – No. of Directors – SR Reference – IPN Directors (Yes/No/NA) – Automated Reply on PPSN (Yes/No)
Example:
Form B1C – 3 Directors – SR1234567 – IPN Directors listed Yes – Automated reply on PPSN holders Yes
Need Help Navigating These Requirements?
Our Company Secretarial team at can assist with:
- Verifying CRO and DSP data consistency
- Filing Form VIF or VIFa on your behalf
- Resolving issues with mismatches or rejected filings
Contact us today to ensure your next CRO filing goes smoothly.
