Ireland: Central Register Of Beneficial Ownership Of Corporates - Deadline For Filing November 2019: Ireland

Since 15 November 2016, companies, ICAVs and most other legal entities incorporated in Ireland 1 ("relevant entities") have been obliged to obtain and maintain up-to-date information on their beneficial owners in the expectation that it would be necessary to submit such information to a central beneficial ownership register.

As anticipated, on 22 March 2019, the Department of Finance signed into law regulations (the "New Regulations") providing for the establishment of a Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (the "Central Register") by the Registrar of Beneficial Ownership of Companies and Industrial and Provident Societies (the "Registrar") 3. The New Regulations replace and restate the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2016 ("the 2016 Regulations").

The Registrar will not be accepting beneficial ownership information for ICAVs. It is understood that a separate central register will be established in due course to deal with beneficial ownership information for these entities. This role will most likely be performed by the Central Bank of Ireland.

In a previous update Who are Your Beneficial Owners? we considered the 2016 Regulations and, in particular, (i) the definition of relevant entities and beneficial owners; and (ii) the obligations of relevant entities and beneficial owners in relation to the compilation and maintenance of beneficial ownership registers ("BOR"). With the exception of the added obligation to obtain PPS numbers of beneficial owners (where such number has been assigned), the matters discussed in that update remain unchanged in the New Regulations.  

In this update we discuss the Central Register requirements - the information to be filed, deadlines and accessibility, as well as other obligations imposed by the New Regulations.

Initial Information to be Delivered to the Central Register 

Existing relevant entities are required to submit the following information by 22 November 2019, 4 and relevant entities incorporated after 22 June 2019 will have five months from the date of incorporation to deliver the same information, to the Central Register:

  • The name, date of birth, nationality and residential address of each beneficial owner;
  • A statement of the nature and extent of the interest held, or the nature and extent of control exercised by, each such beneficial owner; and
  • The PPS number 5 of each beneficial owner to whom a PPS number has been assigned (or such other information as is required by the Registrar). While PPS numbers must be submitted to the Central Register, relevant entities and the Registrar may not otherwise disclose this information and only "hashed versions" (which do not allow the PPS numbers to be determined) shall be stored on the Central Register.

If, having exhausted all possible means, 6 no natural persons are identified as being the beneficial owners or, if there is any doubt that such natural person is a beneficial owner, the relevant entity must file the names of one or more natural persons who hold the position of senior managing official of the relevant entity together with their date of birth, nationality, residential address and PPS number.

Persons Entitled to Access Information on the Central Register

The information contained on the Central Register can be accessed by:

  • Members of the public;
  • Designated Persons; 
  • Bodies such as An Garda Síochána, Financial Intelligence Units, the Revenue Commissioners and the Criminal Assets Bureau; and
  • Competent authorities who are engaged in the prevention, detection or investigation of possible money laundering or terrorist financing.

Information that may be accessed

  • The information accessible by members of the public and Designated Persons is limited to the name, the month and year of birth, the country of residence and nationality of each beneficial owner together with a statement of the nature and extent of the interest held, or the nature and extent of control exercised, by each such beneficial owner.
  • Where a member of the public or a Designated Person seeks to have access to any information that relates to a minor who is a beneficial owner, they must provide a summary of the grounds on which it considers it is in the public interest that the information be disclosed to it. The Registrar can refuse this application if it is of the opinion that there are not substantial grounds for such an access request.
  • An Garda Síochána, Financial Intelligence Units, Revenue Commissioners, Criminal Assets Bureau and other competent authorities listed above (the "Competent Authorities") will be entitled to access all information contained on the Central Register with the exception of beneficial owners' PPS numbers.  

The Registrar is not obliged to notify relevant entities that third parties have accessed their beneficial ownership details contained on the Central Register.

New Obligation Requiring Relevant Entities to Provide Information to Designated Persons

When a relevant entity enters into an occasional transaction, 9 or forms a business relationship, with a Designated Person, the relevant entity must:

  • Provide the Designated Person with information as to its beneficial ownership (in addition to information about its legal ownership) when the Designated Person is taking customer due diligence measures in accordance with Part 4 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010;
  • On request from the Designated Person, provide the Designated Person with information identifying all the beneficial owners of the relevant entity; and
  • Notify the Designated Person of any change to its BOR that is relevant to the occasional transaction or that occurs during the course of the business relationship formed within 14 days from the date on which the relevant entity becomes aware of the change.

Obligations to Report Discrepancies to the Registrar

If Designated Persons, or any Competent Authorities, determine that there is a discrepancy between the information provided to them and the information filed on the Central Register, they must report the discrepancy to the Registrar in a timely manner. The Registrar will then serve a notice on the relevant entity asking them to clarify the discrepancies raised.

Duty to Keep and Maintain a BOR 

The New Regulations oblige relevant entities to ensure that their BORs are maintained and up-to-date.  

This means that if a relevant entity has:

  • Been notified of a change to the information contained on its BOR by a beneficial owner (or with its knowledge), it must update its BOR; or
  • Reasonable cause to believe that there has been a change to the information contained on its BOR, it must send a notice to the relevant beneficial owner seeking such information to allow it to make the necessary updates to its BOR.

Duty to Keep BOR and Central Register Aligned and up-to-date

Any changes that occur in the information contained in a relevant entity's BOR must be reflected by a corresponding change to the Central Register.

Failure to Comply with Filing Obligations on the Central Register

A relevant entity that fails to comply with its obligations under the New Regulations commits an offence and is liable (a) on summary conviction to a class A fine (not exceeding €5,000), or (b) on conviction on indictment, to a fine not exceeding €500,000.

What actions should relevant entities take? 

Relevant entities who have not yet taken steps to obtain and hold information about their beneficial owners should do so now (noting the new requirement to obtain PPS numbers of beneficial owners).

Further Information

Relevant entities should note it is expected that the Central Register will be accessible in advance of filing obligations becoming effective (at the end of April, subject to change) and it may be that the process for filing and information required by the Registrar will develop over time. 


1 The exception is companies listed on a regulated market and subject to disclosure requirements consistent with EU law or subject to equivalent international standards that ensure adequate transparency of ownership information.

2 The exception is companies listed on a regulated market and subject to disclosure requirements consistent with EU law or subject to equivalent international standards that ensure adequate transparency of ownership information.

3 The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019.

4 The obligation to submit information to the Central Register does not commence until 22 June 2019.

5 A PPS number is a personal public service number issued by the Irish Department of Employment Affairs and Social Protection. It is a unique identifier for use in certain transactions with public bodies.

6 See requirements contained in our previous update Who are Your Beneficial Owners?

7 Senior managing officials include directors and chief executive officers of relevant entities.

8 The definition of "Designated Person" includes credit and financial institutions, auditors, relevant independent legal professionals, trust or company service providers, property service providers, persons who provide gambling activities and persons trading in goods that involve cash transactions of at least €10,000.

9 Occasional transaction means a transaction in relation to which the Designated Person is required to apply customer due diligence within the meaning of Part 4 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Similar Articles
Relevancy Powered by MondaqAI
In association with
Related Topics
Similar Articles
Relevancy Powered by MondaqAI
Related Articles
Up-coming Events Search
Font Size:
Mondaq on Twitter
Mondaq Free Registration
Gain access to Mondaq global archive of over 375,000 articles covering 200 countries with a personalised News Alert and automatic login on this device.
Mondaq News Alert (some suggested topics and region)
Select Topics
Registration (please scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions