The Central Register of Beneficial Ownership Ireland maintains records of who ultimately owns and controls Irish-registered entities. Established under the European Union’s anti-money laundering framework, the register aims to increase transparency in corporate ownership structures and help combat financial crime.
At its core, the RBO serves three main purposes:
To create transparency around who ultimately owns and controls Irish companies
To help prevent money laundering and terrorist financing
To fulfil Ireland’s obligations under EU anti-money laundering directives
Understanding who needs to register beneficial ownership in Ireland is the first step toward compliance. The requirement applies to:
All Irish incorporated companies (including Limited and Unlimited companies)
Industrial and Provident Societies
Certain Financial Vehicles (CFVs) through a separate register maintained by the Central Bank
The question of who needs to register beneficial ownership in Ireland extends to both new and existing companies. Even dormant companies must comply with these requirements if they remain on the Companies Register.
Financial vehicles have specific rules regarding who needs to register beneficial ownership in Ireland. These include:
Irish Collective Asset-Management Vehicles (ICAVs)
Unit Trusts
Credit Unions
Investment Limited Partnerships
Common Contractual Funds
It’s worth noting that sole traders, unincorporated associations, and foreign companies operating in Ireland (but not incorporated there) generally fall outside the scope of the RBO requirements.
The Register of Beneficial Ownership (RBO) maintains comprehensive records of all beneficial owners who hold more than a 25% stake in private companies, trusts, industrial and provident societies, and other applicable entities. This transparency measure is designed to provide clarity about who ultimately controls these organisations.
When a company cannot identify any beneficial owners meeting the 25% threshold, the law requires alternative disclosures. In these situations, you must instead file details of directors, senior managers, or any other individuals who exercise dominant influence over the company as the designated "beneficial owners."
The RBO requires specific information for each beneficial owner, who must be a natural person (not a corporate entity). Here's what you need to provide:
Company Details
Company or Society Name
Company or Society Registration Number
Personal Information
Full legal name (must match official records)
Date of birth
Nationality
Country of residence
Complete residential address
Eircode (this is optional but recommended)
Ownership Details
Nature of the beneficial interest (for example, "controlling shareholder" or "trust beneficiary")
Extent of the beneficial interest (such as "holds 33% of voting shares" or "controls 40% of the company")
Date when the person was first recorded as a beneficial owner in the company's internal register
Date when beneficial ownership ceased (if applicable)
Sometimes, despite a thorough investigation, companies cannot identify any natural persons who qualify as beneficial owners under the 25% threshold. In these cases, the law requires you to file details of senior managing officials instead.
Important compliance note: You must maintain detailed records of all steps taken to identify beneficial owners. This documentation demonstrates your due diligence efforts and compliance with Regulation 5(5) of Statutory Instrument 110/2019.
Please note: The forename and surname you submit to the RBO must exactly match the person's legally registered name. The Registrar has the authority to reject any submission where the name provided doesn't correspond with the name associated with the individual's PPS number in the Department of Employment Affairs and Social Protection's records.
This strict name-matching requirement helps ensure the accuracy and integrity of the beneficial ownership information on file.
Compliance with RBO requirements isn't just a legal obligation - it's part of Ireland's commitment to international transparency standards. By maintaining accurate beneficial ownership records, you're helping create a business environment built on trust and accountability.
If you're unsure about any aspect of your RBO filing requirements, we recommend consulting with a qualified professional who can guide you through the process and ensure full compliance with all applicable regulations.
Presenter Requirements
When making an entry to the Register of Beneficial Ownership, you must designate a "presenter" who will handle the submission on behalf of your company or society. This person acts as the official point of contact for your RBO filing and takes responsibility for ensuring the information is accurate and complete.
Required Presenter Information
The following details must be provided for the person submitting your RBO entry:
Contact Details
Full legal name
Complete residential address
Phone number
Email address
Professional Capacity
You must clearly specify the presenter's relationship to your organisation, such as:
Company officer (director, secretary, etc.)
Employee of the company or society
Professional agent acting on behalf of the organisation
Other authorised representative
When the Presenter Isn't an Individual
If your presenter is a corporate entity (such as a law firm or accounting practice), you still need to provide the contact information of a specific natural person within that organisation. This individual will serve as the designated contact for any correspondence related to your RBO filing.
Given the complexity of these requirements and the importance of data protection compliance, working with an experienced professional can save you time and ensure full compliance. Nathan specialises in RBO filings and can assist you in several key ways:
Complete Filing Management
Expert Guidance
Professional Assurance
Contact Nathan Trust to discuss your specific RBO requirements. Whether you need a one-time filing or ongoing compliance support, professional assistance ensures your submission meets all regulatory standards while protecting sensitive personal data throughout the process.
Remember, the presenter you designate becomes the official point of contact for your RBO submission, so working with someone who understands both the technical requirements and data security standards is essential for successful compliance.