Beneficial Owner Register Deadline

Make Haste While the Sun Shines

We are writing to you in respect of a very important deadline concerning the establishment of a Central Register of Beneficial Owners.

The Register itself is overseen by the Department of Finance and the impetus for this EU led legislation has been to increase access, across the EU Member States, to accurate information regarding beneficial ownership.  This, in turn, is seen as critical to the effective deterrence of criminal activities that could be shielded by corporate structures.  As these new requirements are therefore being implemented from legislation designed to target anti-money laundering and terrorist-financing, we do expect the enforcement regime to be severe and uncompromising.
The European Union has legislated for a number of Anti-Money laundering directives over the last few years. The full effect of what are known as the 4th/5th directives comes into effect over an 18 month period from July 2018
On 15th November 2016, a new requirement was introduced for ALL Irish registered companies which imposed on them the necessity to create and maintain an internal Register of Beneficial Owners.

A new online portal went live to facilitate the uploading of information to a central register,

There is a deadline expiring on 22nd November 2019, for compliance for existing companies from the date the central database went live.

A beneficial owner is defined as a person who owns in excess of 25% of a company, directly or indirectly.

It is important to note that the Central Register of Beneficial Ownership is separate and distinct from the Companies Registration Office and the annual filings that a company must make to the CRO.

Some important points in relation to these regulations are as follows:
  • Companies should have created/must now create an internal register of their beneficial owners and ensure this is maintained and updated.
  • In order to have populated, or to now populate, this Register, the company should have sent, or must now send, notices to persons whom they reasonably believe are beneficial owners, or to third parties who may be reasonably expected to know the identities of the beneficial owners
  • This information must be subsequently uploaded through an online portal to the Central Register of Beneficial Ownership
  • Non-compliance is a criminal offence and companies may be subject to fines of up to €500,000 if convicted on indictment.  In addition, a beneficial owner who fails to comply with a relevant notice from the company may also be liable to a 12-month prison term.
The information captured for each beneficial owner is as follows:
  • Name (these details must agree to the records held with the Department of Social Protection)
  • Date of birth
  • PPSN
  • Residential Address (these details must agree to the records held with the Department of Social Protection)
  • Nationality
  • Details of nature and extent of interest held/control exercised by each beneficial owner
  • Date on which the beneficial owner was first entered into the company’s internal register.
If you wish to avail of this service, please complete the attached order form and email to
For further information on this please do not hesitate to contact any of us in Ecovis Dca Ltd. and we will be delighted to assist you. The basic cost of this service will be €295 plus VAT, invoiced directly by EcovisDca Ltd. The fee is payable in advance on the information sheet referred to above. If any unforeseen issues arise on setting up the registration an additional charge may be incurred.
Yours sincerely,
Ecovis Dca Ltd