An email arrives asking to see your Irish LTD's register of members. The sender is not a shareholder you recognise. Should you refuse, send them to the CRO, arrange an inspection or email a copy? This is a different question from which statutory books the company must maintain.
A small private company needs a workable response process, even if it has only one shareholder. This guide covers an ordinary Irish LTD's register-of-members request, with related records used to explain the boundaries. Official sources were checked on 8 November 2026. Disputed ownership, threatened proceedings or an unusual request needs case-specific legal advice.
1. Identify the record, not just the word 'register'
Section 169 requires a company to keep a register of members containing membership particulars, including names, addresses, share information and relevant entry and cessation dates. A summary cap table may be useful, but it should not be assumed to contain everything the statutory record requires.
Ask whether the sender means that company-maintained register, a document filed with the CRO, or beneficial-ownership information. The RBO describes a separate central repository concerning natural persons who ultimately own or control relevant entities. A request for the members' register is not a request for your complete RBO working folder.
Use the company number to resolve similarly named entities. If you administer several companies, find the correct legal entity before opening files. A shared brand, office address or secretary does not make their records interchangeable. Keep the original wording of the enquiry so later clarification does not erase what was initially requested.
2. Do not assume only shareholders can ask
CRO's register-location guidance identifies the members', directors' and secretaries', and disclosable interests registers as records accessible to the general public as well as company members and officers. The fact that an LTD is privately held does not mean its membership register is private to its owners.
For the register of members, distinguish a member's inspection from another person's inspection and from a copy request. If the requester acts for someone else, clarify that capacity where it matters to the route. Do not turn sensible administration into an invented rule that every requester must first become a shareholder.
A bank or prospective investor may also ask for documents through a voluntary due-diligence process. That commercial request can be wider than a statutory inspection. Classify each document separately rather than treating the word 'investor' as authority to disclose the entire company archive.
| Request | Starting point | Do not assume |
|---|---|---|
| Member wants to inspect | Confirm the record and member route | A copy is also free |
| Another person wants to inspect | Check statutory access and applicable fee | Private-company status permits refusal |
| A copy or extract is requested | Use the separate copy timetable | An inspection appointment answers it |
| Investor wants an entire data room | Assess each document and authority | One register right covers everything |
3. Separate an inspection appointment from supplying a copy
Section 216 provides for inspection during business hours, subject to its terms. It separately allows members and other people to request copies of the members' register or part of it. Under subsection (13), the company must send the requested copy within 10 days after receipt of the request, on payment of the relevant fee.
Log receipt immediately and assign a named person to respond. Do not assume that a payment enquiry, internal forwarding email or the secretary's holiday restarts the statutory clock. If payment, scope or delivery is unresolved, obtain prompt advice on the actual obligation instead of treating the request as indefinitely paused.
For inspection, confirm the lawful location, business-hours arrangements, contact and record being made available. For a copy, confirm the portion requested and delivery details. Do not silently substitute one for the other: offering an appointment is not the same task as sending the requested copy.
4. Apply statutory fees, not an invented administration tariff
Section 217 sets the relevant fees. As checked for this guide, one register's inspection by a person other than a member is EUR 10, or a lower sum the company determines. The EUR 15 multiple-register inspection fee has specific same-requester and 24-hour conditions. A copy under section 216(13) is EUR 10 per copy, or a lower sum.
Keep free member inspection distinct from paid copies. Check the actual request and current provisions before quoting a charge. Do not demand a bespoke due-diligence fee as a condition of satisfying an ordinary statutory entitlement, or assume that several emails automatically create several chargeable copies.
These are statutory access charges, not StartCompany.ie's service prices. Any professional work the company commissions to organise records or obtain advice is a separate engagement. Agree that scope and total payable without confusing the company's adviser costs with the requester's statutory fee.
5. Find the register and a person who can actually produce it
A register-location record is useful only if somebody can retrieve the correct version. Confirm who maintains the register, where it can be produced and who covers absences. An address provider receiving the request may not be the person holding the books; avoid leaving the message circulating between several advisers without an owner.
CRO says relevant registers must be maintained within the State and location changes are notified on Form B3 within 14 days. Check the existing notification and actual arrangements if records have moved. Buying an address service does not itself move every register or establish that an inspection can occur there.
Electronic records are not automatically disqualified. Section 215 recognises reproduction by computer in legible, inspectable form at the required place. Test access, readable output and retrieval before promising availability. A cloud login held only by a former adviser is not a practical inspection arrangement.
6. Keep different records and access rights apart
Do not put the whole minute book, payroll folder and identity-verification file beside the members' register simply because they share a cabinet. Start with a document list showing the requested item and any separately requested material. Access to one record is not a universal company-information right.
Section 199 concerns general-meeting proceedings and resolutions. The minutes covered by the section 215 definitions include those books and specified written-resolution records. Do not read that as automatic access to every internal board note, accounting document or legal-advice file. If several categories are requested, assess the applicable right for each.
Likewise, pointing the sender to a CRO search does not necessarily satisfy a request directed to the company for its own register. Public filings, company-maintained records and an investor's bespoke ownership certificate serve different purposes. Explain which item you are supplying rather than calling every ownership document 'the register'.
7. Use proportionate privacy controls without obstructing lawful access
The Data Protection Commission identifies compliance with a legal obligation as one possible lawful basis for processing personal data. Do not assume consent from every member is always needed before complying with a valid statutory request. Equally, the existence of an inspection right does not justify unrelated disclosures.
Check the recipient and delivery route proportionately. A public-access request is not a reason to demand extensive identity documents from everyone. A claim to a member-specific right or an instruction to send material to a representative may need different checks. Obtain advice where authority or a safety concern is genuinely unclear.
Prepare only the relevant record or extract and check attachments before sending. Keep passports, PPSNs, bank details, passwords and other companies' records outside the response. Do not unilaterally remove required register particulars merely because they are personal data; resolve any proposed restriction against the actual legal obligation.
DPC security guidance stresses controlled access and secure handling. In practice, use an appropriate transfer method, restrict staff access and record what was supplied and when. An inspection visitor should not receive unrestricted use of the administrator's computer or browse unrelated cabinet files.
8. Escalate missing records, objections and delays promptly
If entries are missing, preserve the existing record and underlying evidence. Tell the responsible director and adviser what is uncertain. Do not backdate an entry, invent a historic member or quietly replace a disputed record just to make a response look tidy. Reconstruction and an ownership dispute are different assignments from routine administration.
Do not invent an inspection holiday. Section 174 permits closure of the members' register only through its notice mechanism and within an aggregate 30-day annual limit. It is not a general excuse for closing access whenever a request is inconvenient. Get advice before relying on a closure.
Section 217 provides offences for specified failures and court remedies compelling inspection or the sending of copies. If you think a request cannot lawfully be met, obtain company-law advice immediately. An unanswered inbox or a provider invoice is not a defence strategy, and buying a new secretary appointment does not cure an existing failure.
9. Example: an unfamiliar requester asks for a copy
Imagine a fictional two-member consultancy receiving an email from a person outside the company asking for a copy of its register of members. The director initially wants to reply 'shareholders only'. The secretary instead identifies the company, records receipt and classifies the request as a copy rather than an inspection appointment.
They locate the current register, confirm the applicable fee and delivery details, and arrange a response against the statutory timetable. They do not send the entire company binder: it contains identity documents, banking correspondence and another business's papers. Any separately requested material is assessed independently.
If a membership entry is disputed, they preserve the evidence and seek advice rather than rewriting the register to suit the request. The example illustrates a controlled workflow, not approval of a particular disclosure, a document template or a promise that every request can be resolved without legal assistance.
- Identify the legal company and the exact record requested.
- Record receipt, request type, capacity where relevant and responsible contact.
- Locate the maintained register and check the required availability.
- Confirm applicable fee, timetable and delivery arrangements.
- Prepare only the relevant material and check the recipient and attachments.
- Keep the response evidence and escalate unresolved issues promptly.
10. Buy the records support you actually need
Section 226 connects the secretary appointment with appropriate skills for maintaining, or arranging maintenance of, non-accounting company records. Directors should establish a functioning information flow, not assume that a job title or annual renewal means someone has every historical document and authority to answer every request.
StartCompany.ie's Company Secretary Service offers an annual nominee appointment with compliance reminders, officer-filing guidance and statutory-record support. Explain any live request and its receipt date before ordering. Ask whether response coordination or records review can be provided and confirm scope and total payable; do not assume urgent legal advice or historic reconstruction is included.
A registered office, secretary appointment and annual-return filing are separate tasks unless expressly included in the agreement. Decide who receives requests, maintains records, handles lawful access and covers absences. Keep the completion evidence for each task rather than treating one service payment as proof that all obligations have been fulfilled.
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Official information and next steps
Official CRO, RBO and Data Protection Commission guidance and the linked revised Companies Act provisions checked on 8 November 2026. This is an ordinary LTD response checklist, not a legal opinion on a contested inspection, an ownership dispute or a proposed restriction. Confirm current law and the facts of the actual request before relying on a particular response.
- Companies Act 2014, section 169: register of members
- CRO: register location, inspection and Form B3
- Companies Act 2014, section 215: definitions and computer reproduction
- Companies Act 2014, section 216: inspection and copies
- Companies Act 2014, section 217: fees and enforcement
- Companies Act 2014, section 174: register closure
- Companies Act 2014, section 199: general-meeting records
- Companies Act 2014, section 226: secretary duties
- RBO: beneficial-ownership information is a separate record
- Data Protection Commission: lawful processing
- Data Protection Commission: data security guidance