Elaine Breen BlackBee’s General Counsel writes about the new Central Register and its impact
The Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (RBO) officially launched on 29 July 2019, following important clarifications in relation to the requirement to provide PPS numbers for beneficial owners.
The RBO is the central repository of statutory information that must be held by relevant entities in respect of the natural persons who are their beneficial owners/controllers, including details of the beneficial interests held by them.
Relevant entities are:
- companies registered under the Companies Act 2014 or an existing company within the meaning of that Act, and
- industrial and provident societies registered under the Industrial and Provident Societies Acts 1893 to 2018.
Filing of beneficial ownership data with the RBO must be done through an on-line portal that is available at https://rbo.gov.ie/. There are no paper forms or filing fees involved.
Relevant entities now have five months, until 22 November 2019, to file details of their beneficial owners in the RBO without being in breach of their statutory duty to file.
Beneficial owners who do not have a PPS number will be obliged to submit a Declaration as to Verification of Identity containing their name, date of birth, nationality and address. The beneficial owner must solemnly declare this information to be correct and true and have this Declaration verified, witnessed and signed. The RBO will announce further details about this process in due course.
Companies and industrial and provident societies in scope of the Regulations are obliged to file up to date beneficial ownership information with the RBO. There is a maximum penalty of €500,000 for failure to make these filings.