How do I register a Beneficial Owner?

The requirement for corporate and legal entities to hold their own internal beneficial ownership register was introduced with effect from 15 November 2016 by Statutory Instrument No 560 of 2016 and the requirement for companies and societies to file these details with a central register was transposed into Irish law with effect from 22 June 2019 by Statutory Instrument No 110 of 2019.

In accordance with Regulations 5 and 21 of SI 110 of 2019, every relevant entity shall deliver the following information to the Registrar in respect of each beneficial owner of the entity:

• ● First name:
• ● Last name:
• ● Date of Birth:
• ● Personal Public Service Number (PPSN):
• ● Nationality:
• ● Residential address & country of residence:
• ● Statement of the nature & extent of interest held:
• ● Statement of the nature & extent of control exercised:
• ● Company / Society Name as it appears in Register of Companies or I&P Register:
• ● Company / Society Number as it appears in Register of Companies or I&P Register:
• ● Date of entry as beneficial owner:
• ● Date of cessation as beneficial owner:
• ● Presenter Details:
• ● Name of presenter:
• ● Address of presenter:
• ● Phone number of presenter:
• ● e-Mail address of presenter:
• ● Capacity in which the presenter is acting: (eg officer/employee of company/ society, person acting on behalf of the company/society etc).
• ● If the presenter is not a natural person, please enter the name, address, phone number and e-mail address of a natural person for correspondence purposes.
• ● If either,
  • ○ after having exhausted all possible means and provided there are no grounds for suspicion, no natural person is identified, or
  • ○ if there is any doubt that any natural person so identified is a beneficial owner of the relevant entity, there shall be entered in the company/society’s internal register as its beneficial owners, the names and details of the one or more natural person(s) who hold the position(s) of senior managing official(s)(SMO) of the company/ society.

All the same details must be entered in the internal register and in the RBO for an SMO as for any other beneficial owner. Relevant entities shall keep records of the actions taken to identify their beneficial owners. (Regulations 5(4) & (5) of S1 110/2019 refer).

Companies/societies should familiarise themselves with their responsibilities as set out in Regulations 5 and 21 of Statutory Instrument No 110/2019,

1. 1. to maintain an internal register of beneficial owners (Reg 5), and
2. 2. to file data with the central register (RBO)(Reg 21).

Companies/societies and their agents should also be aware of their responsibilities under GDPR for safeguarding any personal data they hold in respect of their beneficial owners.

Entities should seek their own legal advice/opinion to ensure compliance in this regard.

* The forename & surname entered in the RBO Portal must exactly match the name of the natural person, i.e. registered on his/her PPSN with the Department of Employment Affairs and Social Protection.

The Registrar reserves the right to reject any submission where the name entered on the RBO Register does not match the name associated with the PPSN in the Department of Employment Affairs and Social Protection’s records.

All RBO filings must be made online.

A video on “How To” make a new RBO filing is available here: How to Create a New RBO Filing

Login to your RBO account.

On your Dashboard, click on the Start New Filing button at the top of the page

Alternatively, select New Filing from the side menu options

An entity must first be selected, and this option will open on the right-hand side of the application.

Click on the text “Select your Company”.

You can enter either the name or the number for the relevant entity you’re entering Beneficial Ownership details for. Then click on Start

If it is the first entry for the entity, the only option you are presented with is Add New Beneficial Owner.

If it is not the first entry for this entity, you will be presented with list of current Beneficial Owners (name only) and additional options:

• ● Update Beneficial Owner
• ● Remove Beneficial Owner

Remember to click Save and Next at the bottom of the page to progress to the next page.

The first name and last name entered in the RBO must exactly match the first name and last name recorded by the Department of Social Protection (DSP) for the PPSN entered in the RBO. Middle names are not required by the RBO

RBO is legally obliged to validate the identity of the Beneficial Owner entered on the RBO to ensure that the Beneficial Owner is a natural person.

In order to carry out this validation, the name and PPSN entered in the RBO portal will be compared with the Department of Social Protection (DSP’s) records.

As a result, upon entering these details online, the RBO will run an automatic check with the DSP’s database and if the details do not match, it will most likely result in the submission being rejected.

RBO is legally obliged to validate the identity of the Beneficial Owner entered on the RBO to ensure that the Beneficial Owner is a natural person. Therefore, the name entered in the RBO must exactly match the name recorded by the Department of Social Protection (DSP) for the PPSN entered in the RBO. If the details do not match with DSP’s records, it will most likely result in the submission being rejected.

No, there is no requirement to file an annual return for the RBO.

The only requirement to file is where a change has occurred on an entity’s internal beneficial ownership list.

Please see FAQ 11.6 for a step-by-step guide to update an entity’s Beneficial Ownership details on the RBO Portal.

Under Regulation 23(5) you are required to notify any changes of beneficial ownership to the RBO within 14 days of the change to the entity’s internal beneficial ownership register. This includes a change of name or address of an existing beneficial owner and the removal or addition of a beneficial owner.

This can be updated on the RBO Portal by using the ‘Amend Beneficial Ownership’ option under ‘Start New Filing’.

The requirement for corporate and legal entities (“companies/societies”) to hold their own beneficial ownership register was transposed into Irish law by Statutory Instrument No 110 of 2019. The following information is required for each Beneficial Owner:

• ● Company / Society Name:
• ● Company / Society Number:
• ● Surname:
• ● Forename:
• ● Date of Birth:
• ● PPS Number (see also FAQ 12)
• ● Nationality
• ● Country of Residence:
• ● Statement of the nature & extent of interest held:
• ● Statement of the nature & extent of control exercised:
• ● Residential Address:
• ● Eircode (optional):
• ● Date of entry as beneficial owner:
• ● Date of cessation as beneficial owner:
• ● If either,
  • ○ after having exhausted all possible means and provided there are no grounds for suspicion, no natural person is identified, or
  • ○ if there is any doubt that any natural person so identified is a beneficial owner of the relevant entity, there shall be entered in the company/society’s internal register as its beneficial owners, the names and details of the one or more natural person(s) who hold the position(s) of senior managing official(s)(SMO) of the company/ society.All the same details must be entered in the internal register and in the RBO for an SMO as for any other beneficial owner. Relevant entities shall keep records of the actions taken to identify their beneficial owners. (Regulations 5(4) & (5) of S1 110/2019 refer). 
• ● Presenter Details:
• ● Name of presenter:
• ● Address of presenter:
• ● Phone number of presenter:
• ● e-Mail address of presenter:
• ● Capacity in which the presenter is acting: (eg officer/employee of company/ society, person acting on behalf of the company/society etc).
• ● If the presenter is not a natural person, please enter the name, address, phone number and e-mail address of a natural person for correspondence purposes.

Companies/societies should familiarise themselves with their responsibilities as set out in Regulation 21 of Statutory Instrument No 110/2019

1. 1. to maintain an internal register of beneficial owners, and
2. 2. to file data with the Central Register (RBO).

Companies/societies and their agents should also be aware of their responsibilities under GDPR for safeguarding any personal data they hold in respect of their beneficial owners.

Entities should seek their own legal advice/opinion to ensure compliance in this regard.

* The forename & surname entered in the RBO Portal must exactly match the name of the natural person, i.e. registered on his/her PPSN with the Department of Employment Affairs and Social Protection.

The Registrar reserves the right to reject any submission where the name entered on the RBO Register does not match the name associated with the PPSN in the Department of Employment Affairs and Social Protection’s records.

The CORE and RBO portals are not linked and are for two independent and separate Registers. You must create a new and separate account for the RBO Portal to access and use it

No, there is no facility to save a draft of a submission in the RBO Portal.

Please ensure you have all the required details to hand when commencing your RBO submission as data entered cannot be saved and will be lost if the submission is not completed.

It is not possible to view the details of the submissions you have made. This information is restricted for data protection purposes, and the information entered onto the RBO Register should match the information on the entity’s own internal beneficial ownership register.

To retrieve your Login Name:

• ● Click on the Forgot Password option
• ● On the Forgot Password screen, click on the Forgot Login Name option at the bottom
• ● On the Forgot Login Name screen, enter the email address used to register with the RBO Portal
• ● Click Submit

To retrieve your Password:

• ● Click on the Forgot Password option beneath the Login Name and Password fields.
• ● On the Forgot Password screen, enter your Login Name
• ● Click Submit

Under Regulation 23(5) you are required to notify any changes of beneficial ownership to the RBO within 14 days of the change to the entity’s internal beneficial ownership register. This includes a change of name or address of an existing beneficial owner and the removal or addition of a beneficial owner.

This can be updated on the RBO Portal by using the ‘Amend Beneficial Ownership’ option under ‘Start New Filing’.

No, there is no requirement to file an annual return for the RBO.

The only requirement to file is where a change has occurred on an entity’s internal beneficial ownership list.

Please see FAQ 11.6 for a step-by-step guide to update an entity’s Beneficial Ownership details on the RBO Portal.

Additional users need to be added by the RBO unit until further notice. We hope to have the option to add sub users available on the portal in the near future.

If all the Beneficial Ownership details are correct and exactly match the details held by the Department of Social Protection, the submission should register within a short timeframe, usually within minutes.

Under Data Protection legislation, RBO staff cannot discuss individual case details or personal data with a company/society or presenter by phone or email. The RBO Unit can only engage with the data subject that is the beneficial owner in relation to their personal data by e-mail at enquiries@rbo.gov.ie.

The RBO Register is designed to accept and register submissions when all details entered are correct.

Under Data Protection regulations, the RBO does not have access to the personal details entered by the presenter.

Personal details are verified against Department of Social Protection (DSP). They are not verified with the Revenue Commissioners.

The common reasons for a submission rejecting are:

• ● PPSN and/or Date of Birth is incorrect
• ● Entering the DOB incorrectly onto the RBO Portal
• ● Mismatch on name
  • ○ Using maiden name instead of married name and vice versa
  • ○ Using middle name in everyday usage, but not matching with forename as registered with DSP (Paul Smith vs Michael Paul Smith)
  • ○ Using shortened versions of a name (Des/Desmond, Eddie/Edward)
  • ○ Using variations of a name (Bridget/Breege, Ted/Edward)
  • ○ Using Irish version of a name, when English version is registered with DSP (Eibhlínn/Eileen)
  • ○ Using English version of a name, when Irish version is registered with DSP (Eileen/Eibhlínn)
  • ○ Mix-up on entering details for multiple beneficial owners

If the data subject’s details do not match or need to be amended, you can make enquiries with the Department of Social Protection (DSP) by following the steps below:
• Send an e-mail with the name, PPS Number, date of birth and address of the beneficial owner to RBO@welfare.ie
• Attach the following items to the e-mail:
1. a scanned copy of the beneficial owner’s Passport or Birth Certificate or National Identity card,
2. proof of the beneficial owner’s address.
3. in cases where a beneficial owner’s representative, such as an accountant, solicitor, etc. is submitting the e-mail, a scanned copy of a declaration signed by the beneficial owner stating that the representative is acting on their behalf.
• If a Beneficial Owner (BO) holds a Public Services Card (PSC), the name entered on the RBO should match what is displayed on the PSC.
• An e-mail will issue to the requestor when this process is complete.
In cases where difficulties encountered are due to issues not related to the Department of Social Protection, BOs or their representatives should contact the Central Register of Beneficial Ownership of Companies and Industrial & Provident Societies (RBO)

If your submission was rejected, then the details for one or more Beneficial Owners entered was incorrect. The Data Subject for whom the details were incorrectly entered will also be notified in writing.

Under Data Protection legislation, RBO staff cannot discuss individual case details or personal data with a company/society or presenter by phone or email. The RBO Unit can only engage with the data subject that is the beneficial owner in relation to their personal data by e-mail at enquiries@rbo.gov.ie.

If a beneficial owner knowingly or wilfully provides the company/society and/or their presenter with incorrect details such as the wrong PPSN, date of birth, name etc, s/he may face prosecution or other sanctions for providing false information.

Otherwise, if the error is genuine but the RBO Unit is unable to validate the Beneficial Owner because of the incorrect details, the particular submission for that company/society containing the incorrect data will be rejected in its entirety.

Where the details entered on the RBO portal could not be validated, the Beneficial Owner (data subject) will be contacted directly by the RBO Unit via written correspondence. Under Data Protection legislation, RBO cannot contact the presenter regarding the personal data of a Beneficial Owner who for the purposes of Data Protection legislation is the data subject.

RBO staff cannot discuss or contact a presenter about individual case details or personal data by phone or e-mail. The RBO Unit can only engage with the data subject in relation to their personal data by e-mail, at enquiries@rbo.gov.ie.

You will need to start a new filing 

Enter the company name/number to start.

At the bottom of the first screen you should see three options, and click on the Update/Remove Beneficial owner option, then Next.

Click on the Update/Remove button to confirm this is what you wish to do.

Another screen will open, and allow you to select the beneficial owner you wish to amend/remove.

You will need to add all the personal details in again (including PPSN & Date of Birth). This is to ensure the safety and security of details of the person you’re amending.

Click on Save

*Please note, if you are removing a Beneficial Owner who has been added in error, you are advised to use the same date entered as the Start Date as for the End Date

*Please note, it will state ‘No update Beneficial Owners(s) in this list’ if details were not previously updated.  Click on the ‘Update’ to continue.

Please note that if you are removing a beneficial owner the percentage of shareholding does not automatically transfer to the remaining beneficial owner(s) and an additional filing will need to be made to update their shareholding(s).

If you received notification from the RBO Unit that your details were filed with the RBO but were incorrect, you should contact the company/society you are a Beneficial Ownership of, or their representative/presenter, and request them to re-file the correct data for the company/society.
The forename & surname entered in the RBO must match the name of the natural person, registered on their PPSN with the Department of Social Protection (DSP).
The Registrar reserves the right to reject any submission where the name entered on the RBO Register does not match the name as registered on your PPSN with the DSP.
Under Data Protection legislation, RBO staff cannot discuss individual case details or personal data with a company/society or presenter by phone or email. The RBO Unit can only engage with the data subject that is the beneficial owner in relation to their personal data by e-mail at enquiries@rbo.gov.ie.

If you suspect any fraud or illegal activity you are advised to contact the National Economic Crime Bureau of an Garda Síochána or the Corporate Enforcement Authority.

If the data subject’s details do not match or need to be amended, you can make enquiries with the Department of Social Protection (DSP) by following the steps below:

• ● Send an e-mail with the name, PPS Number, date of birth and address of the beneficial owner to RBO@welfare.ie
• ● Attach the following items to the e-mail:
  1. 1. a scanned copy of the beneficial owner’s Passport or Birth Certificate or National Identity card,
  2. 2. proof of the beneficial owner’s address.
  3. 3. in cases where a beneficial owner’s representative, such as an accountant, solicitor, etc. is submitting the e-mail, a scanned copy of a declaration signed by the beneficial owner stating that the representative is acting on their behalf.
• ● If a Beneficial Owner (BO) holds a Public Services Card (PSC), the name entered on the RBO should match what is displayed on the PSC.
• ● An e-mail will issue to the requestor when this process is complete.

In cases where difficulties encountered are due to issues not related to the Department of Social Protection, BOs or their representatives should contact the Central Register of Beneficial Ownership of Companies and Industrial & Provident Societies (RBO).