Perspectives · Company law and registers
Ireland's director identity number sits on the critical path of an appointment
Since 11 June 2023 a director's PPS number has had to be supplied to the Companies Registration Office when a company is incorporated, when an annual return is filed and when a director or secretary changes. A director who has no PPS number applies to the CRO instead for an identified person number, on a declaration witnessed by a solicitor or a notary. The statutory requirement is settled; what moves is the CRO's own procedure for the form, which the office updates administratively, so check the version in use and the way it must be witnessed before an appointment is booked. For a fund group appointing a non-resident director, that puts identity provisioning on the critical path. This perspective is general information, not legal advice.
20 April 2026 · Company law and registers
The 2023 change
Identity became a condition of the filing
Section 35 of the Companies (Corporate Enforcement Authority) Act 2021 was commenced on 11 June 2023. From that date a director's PPS number has to be given on an application to incorporate, on the annual return, and on a notice of a change of director or secretary. The number is used for validation only: it is stored in an irreversible hashed form, it is not published on the register, and the CRO stated at commencement that it is not accessible to its own staff.
The stated purpose was accuracy. One person entered three different ways had been appearing as three people, and the statutory ceiling on directorships was hard to test against a register of names. The measure changed what a complete filing means: a form is finished when each director's identifier matches the details the state already holds against it.
Form VIF
The route for a director with no PPS number
The field cannot be left empty. The director applies to the CRO for an identified person number on Form VIF, declaring name, date of birth, nationality and address. The declaration is signed in front of a witness: in Ireland a practising solicitor, and where it is signed abroad a notary public in that jurisdiction.
The number is issued once the CRO has processed the form, and it is then used on the filings that would otherwise carry a PPS number. The details have to correspond. A filing quoting an identifier that does not match the declared date of birth or name is rejected, and the rejection arrives against the filing, not against the form that caused it. Because the CRO controls the form and its instructions administratively, the current version on CORE is the only reliable statement of what it now requires.
The lead time
The declaration is the item nobody schedules
An Irish-resident director who already holds a PPS number never touches any of this, and the appointment timetable never notices. Appoint a non-resident director in another jurisdiction and the consent to act, the board resolution and the identity declaration all have to be in hand before the change of officers can be notified, while the identifier does not yet exist anywhere.
The declaration needs the director in a room with a solicitor or a notary, a document that has to travel in original form, and then processing time at the CRO before a number comes back. Each step is short on its own. Together they can run past the period allowed for notifying a change of officers, and urgency at the filing end compresses none of it, because the filing cannot be made without the output.
So make identity provisioning a numbered step in the appointment plan, sitting beside the consent to act and the board resolution, and give it a start date as well as a due date. For any candidate without a PPS number the question belongs in the first conversation: do you already hold an identified person number, and if not, when can you get to a solicitor or a notary. That one question moves the constraint from the week of the filing to the week of the decision.
In Alethia
The identifier stays with the person
In Alethia a person is a record in their own right, and each company points at it. One director record carries the identifiers issued to that person, the documents evidencing them, and every appointment they hold across the group, so a second Irish appointment starts from what is already known about the director.
Alethia does not file with the CRO and does not obtain a number on a director's behalf. The rest is ordinary governance: a compliance obligation with a due date on the entity that has to notify the change, the consent and the resolution held against the appointment, an audit trail showing when the identifier was recorded and by whom, and scoped access so a date of birth or an identifier is visible only to the people whose work needs it. The gain is a small one that repeats. Nobody emails a director asking for something the group already had.
Questions
Identity numbers and lead time
Does every director have to obtain a PPS number?
No, and this is the usual misreading. The requirement is to supply a PPS number where the director already has one. A director with none applies to the CRO for an identified person number using Form VIF and uses that number on the relevant filings.
Is a director's PPS number visible on the public register?
No. It is supplied for validation and held in an irreversible hashed form, and the CRO stated at commencement that it is not accessible to CRO staff or to any other party. Your own copy of it is therefore the exposed one, which is an argument for scoping who in the group can see it.
Can a colleague witness the declaration?
No. It must be witnessed by a person in the permitted categories: a practising solicitor in Ireland, or a notary public in the jurisdiction where it is signed abroad. Because the CRO can amend the form and its instructions without legislation, check the current version on CORE before the appointment with the witness is made.
Does a director need a fresh identified person number for each Irish company?
No. Once issued, the number belongs to the person and is used again on every later filing and on every further appointment across the group. Record it against the person when it arrives, together with the declaration that produced it, and the second appointment costs nothing.
Start the identifier before the resolution
Put identity provisioning in the appointment plan with a named owner and a start date, and record the number against the person once it arrives, so the next Irish appointment does not open with an email asking the director for something you already had.