Nathan Trust Blogs

PPS Numbers, Form VIF & IPN | Irish Company Director Requirements

Written by Mark Nathan | Sep 4, 2026, 1:16:03 PM

If you sit on the board of an Irish company and you don't live in Ireland, the Companies Registration Office still needs proof that you are who you say you are. A PPS number does that job. Without one, Form VIF does it instead: a sworn declaration of identity that produces an Identified Person Number, or IPN.

Irish PPS Numbers, Form VIF and IPN are concepts that often confuse non-residents looking to register a company in Ireland and can cause real delays in your process. The IPN covers CRO filings and Register of Beneficial Ownership filings. A Revenue tax reference number is a separate requirement again, for anyone with Irish tax obligations. These are necessary for different bodies, are suited for different purposes, and none of them can be substituted for another.

Which Number do you need?

  CRO Filings Register of Beneficial Ownership Revenue Tax Registration
Who needs it Every director Beneficial owners above the 25% threshold The company, and individuals with Irish tax obligations
If you have a PPSN Use it Use it Use it
If you dont Form VIF → IPN Form VIF → IPN Tax reference number via TR1/TR2
Issuing Body Registrar of Companies Registrar of Beneficial Ownership Revenue
Witnessing Required Yes, in person Yes, in person No

 

There are three separate mechanisms, two of which happen to share a form. A director filing an incorporation document needs a number the CRO recognises. A beneficial owner filing with the RBO needs one the RBO recognises. Anyone with Irish tax obligations needs a Revenue registration on top of either. One person can need all three, or just one, depending on their role within the company.

There's one documented exception. A director who already holds an RBO number can use it for CRO purposes instead of applying for a fresh IPN. The CRO treats the two the same way.

Conflating the three is where founders lose time. If you file an A1 with a Revenue tax number in place of a PPSN or IPN, it will be rejected. If you assume a director's identity number covers a beneficial owner who happens to be a different person you’ll also face rejection. A rejected A1 pushes out your incorporation date.

What a PPS Number is, and whether you can get one

A PPS number is Ireland's personal identifier. The Department of Social Protection issues it for accessing public services and for Irish transactions. Understanding whether you’re eligible or not can save weeks in your application. A PPSN attaches to an Irish entitlement or transaction: employment, social welfare, tax residency, or something comparable. Some non-residents do qualify. Directors relocating to Ireland, working for an Irish employer, or carrying an Irish tax history usually hold a PPSN already, or can apply for one directly. If a board seat is your only connection to Ireland, you won't qualify. Applying anyway and hoping it clears before a filing deadline burns weeks when you should have applied with Form VIF.

Should you apply for a PPSN or go straight to Form VIF?

No Irish employment, no residency, no tax history? Skip the PPSN application and go straight to Form VIF. It's the route the CRO built for your situation, and it saves you weeks on an application that was never going to succeed.

How Form VIF works, and what changed on 30 April 2026

Since midnight on 30 April 2026, the CRO has accepted Form VIF only where the declarant and the witness were physically in the same room. Video-call notarisation, online witnessing, remote commissioning: is now inadmissible as evidence. The Registrar pointed to serious concerns about the integrity of online witnessing.

It's important to clarify the difference between Form VIF and an IPN. Form VIF is the Declaration as to Verification of Identity, the sworn application itself. The Identified Person Number, the IPN, is what that application produces. A “VIF number” doesn't exist.

The declaration covers your name, date of birth, nationality and address. You complete and sign it in the presence of a witness, generally a registered Notary, and the witness also signs it and inputs their details in Part C of the form. The declarant and witness must be physically in the same room when the form is witnessed and signed, the CRO no longer accepts VIF forms witnessed online. The CRO's current guidance sets out the permitted categories of witness, but if you are completing the process outside Ireland, you should check the current requirements with the CRO or your legal adviser before making arrangements.

What the in-person rule means in practice

If you're a director in Bangalore or São Paulo, you will need a witness who can meet you face to face, which is a crucial factor to be built into the plan before you file anything.

Book it first. It now takes longer to arrange than any other part of incorporation.

You only do this once

Once the Registrar issues your IPN, it's yours. Next year's annual return uses the same number and so does your next Irish directorship.

Requirement Detail Common Failure
Witnessing Declarant and witness physically present together Booking a remote or video-call notary appointment
Declaration content Full name, date of birth, nationality, address Name doesn't match the spelling used on the incorporation form
Signature Both declarant and witness sign, same place, same time Signing before or after the witness, or in different locations
Timing Start before other filing steps, given appointment lead time Leaving it until the incorporation deadline is close

 

Beneficial owners: Form BEN2 and the RBO

The Register of Beneficial Ownership isn't part of the CRO's company register. It has its own filing obligation and deadline. A director's CRO filing doesn't cover a beneficial owner, which can cause a lot of confusion in new applicants.

A beneficial owner without a PPSN takes the same route as a director: Form VIF, in person, an IPN at the end of it, recognised by the RBO under the EU's Anti-Money Laundering Regulations. It's a different filing to a different register. If a director is also a beneficial owner, the IPN they already hold doesn't make the RBO filing for them. That filing still has to happen, even where identity has already been verified for the CRO.

Being a director doesn't make you a beneficial owner, as you also require shareholding and control. You're a beneficial owner if you own, directly or indirectly, more than 25% of the company's shares or voting rights, or control it by other means. The threshold sits in Article 3(6) of the EU's Fourth Anti-Money Laundering Directive.

The RBO treats non-compliance seriously. The Registrar can bring legal proceedings against a non-compliant company, separate from anything happening at the CRO.

Is your PPS number visible on the public record?

No. It doesn't appear on any public filing, and the CRO staff processing your documents can't see it either. It's matched against Department of Social Protection records in an encrypted, irreversibly hashed form, and the RBO handles it the same way on its side.

Your registered office address is a different matter. That one is fully public and searchable by anyone, which is the part to weigh if privacy is concerning to you throughout the process.

What happens if you file without a valid number

It gets rejected outright. A filing that carries a PPSN, IPN or RBO number that doesn't match, or carries none at all where one is required, comes back to you, and nothing progresses until the identity requirement is met.

Your incorporation date then becomes the day you resubmit successfully. Every deadline that runs from incorporation moves with it, including your company's first annual return date.

The failures that cost people weeks

The three misunderstandings that cost the most time in Irish company formations are:

  • Booking a remote notary appointment after 30 April 2026.
  • Assuming a Revenue tax reference number will satisfy a CRO filing.
  • A name on the passport that doesn't match the name on the incorporation form character for character.

The in-person VIF appointment has the longest lead time of anything in this process. Start it before you finalise the other incorporation documents, rather than finding out it's the bottleneck once everything else is ready to file.

Frequently Asked Questions:

Can I register an Irish company without a PPS number?

Yes. A director without one files Form VIF and uses the Identified Person Number the Registrar issues instead.

What is a VIF number?

There isn't one. Form VIF is the application, and the Identified Person Number, the IPN, is what it produces. The two names get used interchangeably and shouldn't be.

Can I still get a Form VIF witnessed online?

Not since 30 April 2026. The declarant and the witness have to be physically together.

How long does an Identified Person Number take?

The CRO hasn't published a fixed turnaround for the IPN itself. The witnessing appointment is usually the longest step in the sequence now that it has to happen in person, so book that first.

Is my PPS number visible to the public on CRO records?

No. It's retained in encrypted, hashed form, and it isn't visible to the public or to the CRO staff processing your filing.

Do I need a Section 137 bond as well as an IPN?

Yes, and the two are unrelated. The Section 137 bond applies if your company has no EEA-resident director. The PPSN or IPN requirement applies to every director, wherever they live. Plenty of non-EEA founders need both.