PPSN – Why it’s required and what to do if you don’t have one

Member States are obliged by Article 30(4), 4AMLD, to “ensure that the information held in the central register is adequate, accurate and current”. Therefore, RBO is legally obliged to validate the data entered on the RBO to ensure it is accurate and to ensure that the Beneficial Owner is alive and is a natural person.

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 DSP.

The PPSN will be retained securely in an irreversible hashed/encrypted format and will not be accessible by any member of the RBO Unit or any other party. When the data filed with the RBO has been validated the PPSN will be hashed and stored securely. It will never be shared with any third party.

Obtaining the PPSN is essential for the RBO to comply with the legal requirement in 4AMLD and 5 AMLD for the Register to be “accurate”, for the identity of every beneficial owner to be thoroughly validated and to minimise the possibility of duplicate entries.

The reason for retaining a hashed version of the PPSNs is to allow RBO to match future filings to existing individuals on the register with certainty and avoid duplication.

Hashing is an encryption function to protect data on the RBO in the event of a data breach. This technique will take the PPSN, apply a complex mathematical function to it, to produce a longer unique number that bears no resemblance to the number hidden. With hashing, RBO will never be able to reverse the newly generated number back into a PPSN again.

Yes, it is required each time a Beneficial Owner is added, or where their details are changed, such as a change of address, or details of the shareholding, or other controlling means are updated.

Member States are obliged by Article 30(4), 4AMLD, to “ensure that the information held in the central register is adequate, accurate and current”.

Regulation 21(2) of SI 110/2019 requires that the PPSN be delivered to the Registrar by the relevant entity “for the purpose of verification of the information delivered under Regulations 20(1) or (2)”.

RBO verifies the name, date of birth and PPSN entered in the RBO by comparing them, via an electronic interface, with data held on the PPSN 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 RBO must exactly match the name associated with that PPSN in the DSP’s database.

The Registrar reserves the right to reject any submission where the name entered on the RBO does not match the name as registered for that PPSN with the DSP.

This process allows RBO to verify the identity of each beneficial owner, prove that they are a natural person and minimise the possibility of duplicate entries.

The Registrar of Beneficial Ownership is obliged by law to verify the identity of every beneficial owner in order to comply with the EU Directive that requires the register to be “adequate, accurate and current”.

For beneficial owners who have a PPSN, the RBO will verify their identity against data already verified by the Department of Social Protection (DSP) in respect of that person.

For beneficial owners who do not have a PPSN, the Registrar has determined under Regulation 21(2)(b), SI 110/2019, that the Form VIF – Declaration as to Verification of Identity – will be the method to be used to verify the person’s identity.

Only one VIF will be required in respect of each beneficial owner and once this has been processed successfully and an VIF Number issued by the CRO that VIF Number can be used for making future beneficial ownership filings for that person.

More information is available on the CRO’s website including the form VIF by clicking Here

The BEN2 has been replaced by the Form VIF on the CRO.

The Form VIF is the method that the Registrar has determined under Regulation 21(2)(b), SI 110/2019, will be used for the purpose of verification of a person’s identity where the beneficial owner 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 beneficial owner. The beneficial owner must solemnly declare this information to be correct and true and have this Declaration verified, witnessed and signed.

Any relevant entity that fails to file a PPSN with the VIF number where such a number has been assigned to a beneficial owner, and/or submits a BEN2 application where a PPSN exists for the beneficial owner, will have committed an offence and attention is drawn to Regulations 28(5) and 28(7) of S1 110/2019 in this regard:

28(5): A person who, in purported compliance with Regulation 20, 21, 22 or 23, makes a statement that is false in a material particular, knowing it to be so false or being reckless as to whether it is so false, commits an offence and shall be liable –

1. 1. on summary conviction, to a class A fine or imprisonment for a term not exceeding 12 months or both, or
   2. on conviction on indictment, to a fine not exceeding €500,000 or imprisonment for a term not exceeding 12 months or both.

28(7):Where an offence under these Regulations is committed by a body corporate and is proved to have been so committed with the consent or connivance of any person, being a director, manager, secretary or other officer of the body corporate, or a person who was purporting to act in such capacity, that person shall, as well as the body corporate, be guilty of an offence and shall be liable to be proceeded against and punished as if he or she were guilty of the first-mentioned offence.

More information is available on the CRO’s website including the form VIF by clicking Here

If you have additional beneficial owners for the relevant entity who have PPSNs, you can continue your submission for them and return to add the new beneficial owner upon completion and receipt of the VIF Number application process.

So long as it is for the same beneficial owner as the identified person on the Form VIF. This is their VIF Number and should be used for all RBO related activities for that beneficial owner.

If the beneficial owner is also a director they will also be required to use this same number to file with the CRO.

More information is available on the CRO’s website including the form VIF by clicking Here

The VIF Number will act in place of the PPS Number, but only for beneficial owners with no PPSN. When adding a new beneficial owner with no PPSN, you can use the VIF Number instead of the PPS Number.

No, you do not, if it is for the same beneficial owner/director as identified on the Form VIF.

However, a new VIF Number must be applied for each individual person who is a beneficial owner but for whom a PPS Number has not been issued.