As previously reported, the Central Register of Beneficial Ownership of Companies and Industrial & Provident Societies (RBO) has been accepting filings since 29 July 2019.
We understand that, to date, only a small percentage of entities required to file beneficial ownership information with the RBO have actually done so. All companies and industrial and provident societies in scope of the beneficial ownership legislation must make their filings with the RBO by 22 November 2019 or risk incurring a maximum fine of €500,000.
All filings must be made online via the RBO portal and there is no filing fee.
The information that must be filed for a beneficial owner includes:
- Name
- Date of birth
- Nationality
- Residential address
- A statement of the nature and extent of the interest held, or control exercised, by that person
- Date on which the person was first added to the internal register as beneficial owner
- PPS number or transaction number
Beneficial owners who do not have a PPS number are 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, sign the Declaration and have it witnessed (for example by a notary public). The RBO has made a Form BEN2 available for this purpose, which should be uploaded to the RBO Portal once completed.
For more detail on this topic, see our Client Briefing on the requirements under the beneficial ownership legislation here.
William Fry is available to advise you on the obligations in relation to disclosure of beneficial ownership and the steps that need to be taken to comply with the 2019 Regulations.
