Ireland: Central Register Of Beneficial Ownership Of Companies

Last Updated: 11 April 2019
Article by Terence Pay

The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 (S.I. No. 110 of 2019) (the "Regulations") were issued by the Irish Finance Minister on 22 March 2019.

The Central Register of Beneficial Ownership ("CRBO") required to be established by the Regulations will begin to accept filings of beneficial ownership information from 22 June 2019. Existing Irish companies will have until 22 November 2019 to make their filings (while companies incorporated after 22 June 2019 will have 5 months from incorporation). The CRBO website, which will launch on 29 April 2019, will provide further information and companies will also be contacted directly in the coming weeks with details of their filing obligations.

Companies incorporated in Ireland were already required to maintain an internal register of beneficial ownership information; however, the law requiring maintenance of an internal register (S.I. No. 560 of 2016) has now been repealed and replaced by the Regulations.


The EU's Fourth Anti-Money Laundering Directive ("4AMLD") requires every EU Member State to create a CRBO for companies. The provisions of 4AMLD were required to be given effect in domestic law by 26 June 2017. Ireland was among Member States referred to the Court of Justice of the EU in July 2018 for failing to have implemented 4AMLD in full.

In the meantime, 5AMLD (the successor to 4AMLD) has been adopted by the EU and Member States are now required to bring its provisions into effect by 10 January 2020.

Rights of access to the Irish CRBO

5AMLD requires company CRBOs to be accessible to "any member of the general public" (with the option to require registration and payment of a minimal fee in order to gain such access), whereas 4AMLD provides that members of the public could be required to demonstrate a "legitimate interest" in the information before being granted access.

Under the Regulations, the general public will have "restricted" rights of access to information on the CRBO; however, access is only "restricted" in the sense that not all particulars of beneficial owners will be visible (in particular the day of the date of birth, residential address and PPS/tax ID number). The only exception is where the beneficial owner whose personal information is sought is a minor (child); in this scenario the person seeking access will be requested to set out in writing the "grounds on which he or she considers it is in the public interest that the information be disclosed to him or her". The Regulations allow the registrar to charge a fee for access, but such fee must not exceed the administrative costs of providing access (and it is not yet clear if such a fee will in fact be charged).

Law enforcement and competent authorities in Ireland will have unrestricted access to the CRBO; however that access is to be available only to relatively senior officers of such authorities, and only with the approval of officers of even higher seniority.

There are provisions for Irish law enforcement bodies to exchange CRBO information with equivalent competent authorities in other Member States upon request; as well as for Ireland's CRBO to be interconnected with those of other Member States through the "Central European Platform" potentially envisaged by 5AMLD.

Definition of "beneficial ownership"

The definition of "beneficial ownership" for the purposes of Ireland's CRBO is that contained in 4AMLD, i.e.:

"[T]he natural person(s) who ultimately owns or controls a legal entity through direct or indirect ownership of a sufficient percentage of the shares or voting rights or ownership interest in that entity, including through bearer shareholdings, or through control via other means".

"Sufficient percentage" means more than 25% in the case of direct ownership by a natural person. In cases of indirect ownership, i.e. where ownership interests in an Irish company are held by another entity, any natural person who controls that other entity will be attributed its ownership interests in the Irish company for the purposes of identifying the natural persons who are, ultimately, the beneficial owners.

If after investigating it is found that there are no natural persons who fall within this definition of beneficial ownership, the "senior managing official(s)" (which includes directors and the chief executive) of the Irish company will be considered its beneficial owners. In this scenario, the Irish company must keep records of actions taken to identify the beneficial owners.

Procedures to identify beneficial owners, make filings and ensure accuracy of the CRBO

Natural persons believed to be beneficial owners must be served with a notice by the Irish company asking for confirmation of whether he/she is a beneficial owner and, if so, confirmation of the particulars required to be registered (details of which are included below). The notice must state that a response is required within one month. The serving of notices can be avoided if the person's status as a beneficial owner has already been confirmed to the Irish company and their necessary particulars provided, either by the beneficial owner in question or with his/her knowledge.

Notices can also be served on any other person requiring them to confirm if they know the identity of the beneficial owner (or information from which the beneficial owner can be identified), or the identity of anyone else likely to have such knowledge.

If an Irish company knows or has reasonable cause to believe that a change in beneficial ownership has occurred, it must serve similar such notices (again requiring a response within one month) in order to determine whether a change has occurred, the date of the change and the necessary particulars of the new beneficial owner(s). There is a general duty imposed on Irish companies to keep CRBO filings up to date and to notify changes within 14 days.

Furthermore, a duty is imposed on beneficial owners themselves to notify the Irish company in writing of their status and particulars in circumstances where they have not received a notice. A similar duty applies to beneficial owners to notify changes.

Designated persons and Irish competent authorities who believe they have discovered any discrepancy in CRBO filings are required to serve notice of such opinion on the Registrar, who will then follow the matter up with the Irish company.

CRBO filings will be made through an online portal only. CRBO filings are required to be deleted and destroyed by the Registrar 10 years following the dissolution of the Irish company.

Personal information ("particulars") of beneficial owners to be included in CRBO filings

The particulars of beneficial owners to be included in CRBO filings include the following:

  1. Name, surname and date of birth
  2. PPS number (this is an Irish tax ID number, but there is a provision for alternative information to be provided, i.e. presumably a foreign equivalent)
  3. Nationality
  4. Country of residence
  5. Nature and extent of interest/control
  6. Residential address
  7. Date of entry as beneficial owner (and date of cessation)

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