Beneficial Owners Register
Plan your expenses and deductions strategically each year
Egestas tincidunt ipsum in leo suspendisse turpis ultrices blandit augue eu amet vitae morbi egestas sed sem cras accumsan ipsum suscipit duis molestie elit libero malesuada lorem ut netus sagittis lacus pellentesque viverra velit cursus sapien sed iaculis cras at egestas duis maecenas nibh suscipit duis litum molestie elit libero malesuada lorem curabitur diam eros.
- Morbi fringilla molestie magna sed dictum. Praesent pharetra turpis augue.
- Cras mi purus, viverra vitae felis sit amet, tincidunt fringilla lorem.
- non mattis urna ex nec sem. Donec varius diam et suscipit venenati proin tincidunt
- Quisque euismod posuere lacus sit amet volutpat. Praesent vel imperdiet
Maintain accurate and organized financial records for easy reporting
Tincidunt pharetra at nec morbi senectus ut in lorem senectus nunc felis ipsum vulputate enim gravida ipsum amet lacus habitasse eget tristique nam molestie et in risus sed fermentum neque elit eu diam donec vitae ultricies nec urna cras congue et arcu nunc aliquam at.
Talk to a tax professional for expert guidance
At mattis sit fusce mattis amet sagittis egestas ipsum nunc scelerisque id pulvinar sit viverra euismod. Metus ac elementum libero arcu pellentesque magna lacus duis viverra pharetra phasellus eget orci vitae ullamcorper viverra sed accumsan elit adipiscing dignissim nullam facilisis aenean tincidunt elit. Non rhoncus ut felis vitae massa mi ornare et elit. In dapibus.
- Morbi fringilla molestie magna sed dictum. Praesent pharetra turpis augue.
- Cras mi purus, viverra vitae felis sit amet, tincidunt fringilla lorem.
- non mattis urna ex nec sem. Donec varius diam et suscipit venenati proin tincidunt
- Quisque euismod posuere lacus sit amet volutpat. Praesent vel imperdiet
Personalized Marketing: AI helps in analyzing customer data to create personalized marketing campaigns
At mattis sit fusce mattis amet sagittis egestas ipsum nunc. Scelerisque id pulvinar sit viverra euismod. Metus ac elementum libero arcu pellentesque magna lacus duis viverra. Pharetra phasellus eget orci vitae ullamcorper viverra sed accumsan. Elit adipiscing dignissim nullam facilisis aenean tincidunt elit. Non rhoncus ut felis vitae massa. Elementum elit ipsum tellus hac mi ornare et elit. In dapibus.
“Amet pretium consectetur dui aliquam. Nisi quam facilisi consequat felis sit elit dapibus ipsum nullam est libero pulvinar purus et risus facilisis”
Use accounting and tax software to make management easier
Placerat dui faucibus non accumsan interdum auctor semper consequat vitae egestas malesuada quam aliquam est ultrices enim tristique facilisis est pellentesque lectus ac arcu bibendum urna nisl pharetra bibendum felis senectus dolor commodo quam elementum sapien suscipit qat non elit sagittis aliquam a cursus praesent diam lectus tellus mi lobortis in amet ac imperdiet feugiat tristique nulla eros mauris id aenean a sagittis et pellentesque integer ultricies sit non habitant in cras posuere dolor fames.
Register of Beneficial Ownership (RBO): A Practical Compliance Guide For Company Directors.
For Irish companies, compliance with the Register of Beneficial Ownership (RBO) is not optional. Failure to comply can result in fines, delays with banking and lending applications, and potential legal consequences for directors.
This guide explains what the RBO is, who qualifies as a beneficial owner, what information must be reported, key filing deadlines, and the consequences of non-compliance.
What Is the Register of Beneficial Ownership?
The Register of Beneficial Ownership (RBO) was introduced in July 2019 following the implementation of Article 30(1) of the EU's Fourth Anti-Money Laundering Directive (4AMLD).
The purpose of the register is to identify the individuals who ultimately own or control Irish companies. By increasing transparency, the RBO assists law enforcement agencies and regulatory authorities in combating money laundering and terrorist financing.
Most Irish companies are required to maintain and file beneficial ownership information with the RBO. Newly incorporated companies are generally required to complete their initial filing within five months of incorporation.
Who Is a Beneficial Owner?
A beneficial owner is:
"The natural person(s) who ultimately owns or controls a legal entity through direct or indirect ownership of a sufficient percentage of shares, voting rights or ownership interests, or through control via other means."
In practice, a beneficial owner is an individual who directly or indirectly:
• Owns more than 25% of the company's shares.
• Controls more than 25% of the voting rights.
• Holds more than 25% ownership interest in the company.
• Exercises control over the company through other means.
What If No Individual Meets the Threshold?
Where no individual satisfies the criteria above, the company must record the details of its senior managing officials, such as directors and the CEO.
The company must also retain records demonstrating the steps taken to identify any beneficial owners before registering senior management officials instead.
How Should Companies Identify Beneficial Owners?
Companies are required to take reasonable steps to identify their beneficial owners.
Where a company believes an individual may be a beneficial owner, it must issue a formal notice requesting confirmation of:
• Whether they are a beneficial owner.
• The information required for inclusion in the company's beneficial ownership register.
The recipient must respond within one month.
If the company becomes aware, or reasonably believes, that beneficial ownership has changed, further notices must be issued to determine the nature of those changes.
Are There Any Exemptions?
Most companies and industrial & provident societies registered in Ireland must file beneficial ownership information.
The main exemption applies to companies whose securities are listed on a regulated market that is subject to EU disclosure requirements or equivalent international transparency standards.
What Information Must Be Filed?
The following information must be submitted for each beneficial owner:
• Full name
• Date of birth
• PPS Number (or alternative verification documentation where applicable)
• Nationality
• Country of residence
• Residential address
• Nature and extent of ownership or control
• Date they became a beneficial owner
• Date they ceased to be a beneficial owner (where applicable)
Beneficial Owners Without a PPS Number
Each beneficial owner must provide a PPS Number for filing purposes.
Where an individual does not have a PPS Number, they must complete a Verification of Identity Form (VIF).
The VIF is used to verify the individual's:
• Name
• Date of birth
• Nationality
• Residential address
The completed declaration must be witnessed by a notary public.
Further information on the VIF form can be found here:
Who Can Access RBO Information?
Access to RBO information is no longer available to the general public.
Following a November 2022 ruling by the Court of Justice of the European Union, unrestricted public access was deemed to interfere with privacy and data protection rights.
Since June 2023, applicants seeking access must demonstrate a legitimate interest. This generally applies to persons or organisations involved in:
• Preventing, detecting or investigating money laundering.
• Preventing, detecting or investigating terrorist financing.
• Investigating companies linked to individuals convicted of money laundering or terrorist financing offences.
• Examining companies connected to assets located in high-risk third countries.
Key Filing Deadlines
New Companies:
A newly incorporated company must submit its initial RBO filing within five months of incorporation.
Changes to Beneficial Ownership
Any changes to beneficial ownership details must be filed within 14 days of the change taking effect.
Examples include:
• A new beneficial owner being appointed.
• A beneficial owner ceasing to qualify.
• Changes to personal information or ownership percentages.
How Often Must the Register Be Updated?
Maintaining accurate RBO information is an ongoing obligation.
Companies should regularly review their ownership structures and ensure any changes are recorded promptly to avoid non-compliance.
Penalties for Non-Compliance
Failure to comply with RBO requirements is a criminal offence.
Penalties can include fines of up to €5,000 on summary conviction and up to €500,000 upon indictment.
Importantly, directors and company secretaries remain responsible for compliance even where filing responsibilities have been delegated to an accountant, company secretary provider or other advisor.
Why RBO Compliance Matters
In addition to the risk of fines and prosecution, inaccurate or missing filings can create practical difficulties for businesses.
Banks, lenders and other regulated entities routinely verify RBO compliance as part of their anti-money laundering due diligence procedures.
Where discrepancies exist, companies may experience delays when:
• Opening bank accounts.
• Applying for loans or funding.
• Completing acquisitions or investments.
• Engaging with regulated professional service providers.
Maintaining an accurate RBO filing helps avoid unnecessary delays and demonstrates good corporate governance.
How DBASS Can Help
Understanding beneficial ownership requirements can be challenging, particularly where ownership structures are complex or changes occur frequently.
DBASS can help you identify your beneficial owners, review your compliance obligations and ensure your RBO filings remain accurate and up to date.
Contact us today at info@dbass.ie or 01 849 8800 to discuss your requirements.
For further information, visit the RBO website
