Does an Irish Company Secretary Need a PPSN or IPN?

1. Identify whose identity number the filing requires

Section 888A requires a director to supply a PPSN, or the alternative identity information determined by the Registrar where the director has none, for the specified incorporation, annual-return and officer-change filings. Its wording includes a notice of change of directors or secretaries. That does not turn the appointed secretary into a director.

The practical conclusion is role-specific: a secretary-only appointment does not, by itself, trigger that director requirement. This is a reading of the director-specific provision, not an exemption from every identity check. Ask the presenter which person, capacity and field a request concerns before deciding that the proposed secretary needs an IPN.

• Companies Act 2014, section 888A: director-specific identification
• CRO: 2026 VIF update and the specified director filings

2. No secretary PPSN requirement does not mean no personal particulars

Section 149 distinguishes the information kept for an individual secretary from the details for a corporate appointee. For an individual, the prescribed register particulars include the name, relevant former names, usual residential address and date of birth, subject to the section's qualifications. Absence of a PPSN question does not remove these requirements.

For a body corporate, the record concerns its corporate name and, if registered, its registered office, register and registration number. Identify the legal appointee rather than only a trading brand or the employee answering your emails. A corporate registration number is not a substitute personal identifier in a director's PPSN or IPN field.

Keep a simple role list for the presenter. The comparison below is a triage aid, not a complete filing specification. A person can appear in more than one row, and each capacity must be assessed on its own facts.

• Companies Act 2014, section 149: individual and corporate secretary particulars

3. Check eligibility, consent and the appointment process

A willing person is not automatically a suitable appointee. Section 129 requires directors to ensure that the secretary has the necessary skills or resources. A sole director cannot also hold the secretary office. Having a PPSN does not cure that separate-person problem, and lacking one does not prove a suitable secretary is ineligible.

Section 131 sets a minimum age of 18 for an individual secretary. Review any other eligibility concern with the adviser before appointment. Do not use a professional service merely to avoid asking whether the proposed individual understands the work and is able to perform it.

CRO guidance distinguishes the first secretary identified on incorporation from subsequent changes notified on Form B10. Officer details must be kept current, and relevant changes are notified within 14 days. Agree the decision, consent, effective date and presenter responsibility before filing. An unanswered identification question does not itself extend that deadline.

• Companies Act 2014, section 129: suitability and a sole director's separate secretary
• Companies Act 2014, section 131: minimum age
• CRO: appointment procedures and secretary duties
• CRO: officer changes and the B10 notification period

4. Assess RBO status separately from the secretary appointment

The RBO concerns natural persons who ultimately own or control the entity, including control through means other than a straightforward shareholding. Holding the secretary office is not, on its own, the beneficial-ownership assessment. Equally, the job title does not rule out the person being relevant because of their ownership or actual control.

The RBO also explains the senior-managing-official fallback where its conditions are met. Do not assume that naming an external secretary removes the need to identify the actual owners, or that every secretary must automatically be entered as an SMO. Record the reasoning and obtain advice if the structure or control arrangements are unclear.

Where a person is identified for an RBO filing, the identity-number question follows that separate filing. RBO guidance requires the relevant personal data for an SMO as well as for another beneficial-owner entry. Telling the RBO that someone is 'only our secretary' does not answer a request if the company has identified that person in a different relevant capacity.

• RBO: beneficial ownership, control and senior managing officials
• RBO: information required for beneficial owners and SMOs

5. Use the correct no-PPSN route when another capacity needs it

For a relevant beneficial owner without a PPSN, RBO guidance describes the VIF identity-verification process and an Identified Person Number, or IPN. It says the same person's issued number can be used for later filings, including CRO filings where that person is also a director. Do not order a fresh number for every company or transaction without checking the existing record.

First establish whether the person already has a PPSN or an earlier relevant identifier. A forgotten number is not the same as never having been assigned one. CRO says the IPN route is not open to an Irish citizen resident in the State, full-time or part-time; check the person's actual circumstances rather than treating IPN as the universal option for an empty field.

CRO's current notice also says that, from midnight on 30 April 2026, it no longer accepts online witnessing of VIF forms. The witness and declarant must be physically together, and the updated form must be used. If a VIF is genuinely needed, check the current instructions before arranging a witness. Our separate witnessing guide covers the preparation in more detail.

• RBO: PPSN, VIF and reuse of a person's IPN
• CRO: IPN eligibility and beneficial owners without a PPSN
• CRO: VIF witnessing update dated 29 April 2026

6. Separate provider onboarding from the statutory field

StartCompany.ie's secretary service involves reviewing the company setup and requesting the supporting documents needed for the appointment. A provider's request for identification or authority is not necessarily a statement that section 888A requires the secretary's PPSN. Ask what the requested document establishes and how it should be supplied.

For example, distinguish verification of the person instructing the provider, confirmation of the appointed secretary's particulars, and identification of a director or beneficial owner. A single onboarding pack may cover several of those questions. Labelling the whole pack 'secretary documents' can conceal which requirement remains unresolved.

Use the agreed secure channel and supply only what is requested for the stated purpose. Do not place PPSNs, passport copies, bank credentials or a full identity file into public enquiry forms, checkout notes or a shared public link. RBO guidance specifically reminds companies and agents of their responsibilities to safeguard personal data.

• RBO: safeguarding personal information held by entities and agents

7. Two fictional examples show why the role list matters

In the first example, Ana is the sole director and owner of a new LTD. Lea, an eligible overseas colleague, agrees to act only as secretary; the facts do not identify Lea as a beneficial owner or an RBO senior managing official. Ana should not assume that Lea needs an IPN merely to take the secretary office. They still arrange Lea's consent, correct particulars and a workable administration process, while Ana's director and ownership requirements are addressed separately.

In the second example, Ben is both secretary and one of two directors. He has no PPSN. His secretary appointment does not remove the director identity question. The presenter assesses the applicable director route and any existing identifier, instead of marking his director details 'not applicable' because he also performs secretarial work.

These examples assume the stated roles are genuine. They are not workarounds for concealing control or avoiding director duties. If the person actually performs another role, update the brief and obtain the corresponding advice before submitting the filing.

8. Send a role-specific brief before paying for extra work

A short, accurate brief is usually more useful than sending a bundle of identity documents without context. State the question first, then let the presenter confirm which secure documents and filing instructions are needed. Use this checklist before purchasing an additional service:

• Name the proposed legal appointee and say whether it is an individual or a corporate secretary.
• List any additional director, ownership, control or relevant SMO capacity separately.
• Identify the task: first appointment, B10 change, annual-return work or RBO filing.
• Ask which person's identity field is incomplete and why that identifier is needed.
• Check whether an existing PPSN or relevant IPN record needs to be located or corrected.
• Agree consent, effective dates, outstanding deadlines and responsibility for submission.
• Confirm the secure delivery channel, supporting documents, inclusions and total payable.
• Keep the final appointment and filing evidence, not just a checkout receipt or quotation.

9. Buy the appointment or filing support you actually need

StartCompany.ie offers a 12-month nominee company secretary engagement with CRO compliance reminders, officer filing guidance and statutory-record guidance. The published service does not automatically include annual-return preparation, a registered office, share changes or other filings unless expressly agreed. A secretary-change filing is a separate service from the ongoing appointment.

If the proposed secretary is suitable and only the purpose of an identity request is unclear, resolve that question before replacing them or buying IPN assistance. If no suitable separate secretary is available, compare professional appointment support. If an existing appointment must change, identify the filing and handover work as well as the continuing engagement.

Compare the current inclusions and total payable, explain the actual roles and ask for the required checks before ordering. Payment is not itself an appointment, an issued IPN or CRO acceptance. Nor does appointing a secretary determine director residence, tax treatment, banking approval or immigration permission.