BENEFICIAL OWNERS WHO DO NOT HAVE A PPSN


The Registrar of Beneficial Ownership is obliged by law to verify the identity of beneficial owners in order to comply with the EU’s Fourth Anti-Money Laundering Directive that requires the register to be “adequate, accurate and current”.

For beneficial owners who do not have a PPSN, the Registrar has determined that the Form BEN2 - Declaration as to Verification of Identity - will be the method used to verify the person’s identity.

The BEN2 serves two purposes. It enables the Registrar to verify the identity of a beneficial owner who does not have a PPSN and it is an application for an RBO Number which can be used in all future RBO filings for that person unless he/she obtains a PPSN, in which case the PPSN must be used.

The fillable BEN2 form is currently available to download from the RBO Website at www.rbo.gov.ie and from the RBO Portal which can be accessed through the RBO website. The facility to upload the completed BEN2 and apply for an RBO Number is NOW LIVE.

Only one BEN2 is required in respect of each beneficial owner and once this has been processed successfully and an RBO Number issued by the Registrar, that RBO Number can be used for making future beneficial ownership filings for that person.

The BEN2 form requires the beneficial owner to sign a statement saying that they do not have a PPS number assigned to them. Any relevant entity that submits a BEN2 application containing such a statement knowing that it is false, commits an offence and is liable to prosecution. For more information visit FAQ No 12 on the RBO website - https://www.rbo.gov.ie/faqs.html.  

Helpful Hints in relation to the BEN2 form:

  • Please ensure that the first name, last name and date of birth entered in the RBO Portal are exactly the same as the information on the BEN2 form. Otherwise the BEN2 application may be rejected.
  • Middle names are NOT required on either the BEN2 form or in the RBO Portal.
  • Part A of the BEN2 must be completed fully and either Part 2 OR Part 3 signed by the Declarant (the beneficial owner) and signed & stamped by the witness (eg the Notary Public).
  • Since the BEN2 upload facility went live, a high number of BEN2 forms have been filed. As each individual form must undergo a visual check, it may take a number of days before an RBO Number is issued. In the meantime, please no not submit a second BEN2 form for the same person.
  • Once you have received an e-mail to say the BEN2 has been received, no further action is required – an e-mail with the RBO Number or a Rejection e-Mail explaining the reason for rejection will be issued in a matter of days.
  • Presenters are requested to inform each beneficial owner of their RBO Number as they may need it to file with the RBO for another company which may be using a different presenter.

Further Information:

  • More information, FAQ’s, and videos on how to file with the RBO are available at www.rbo.gov.ie.
  • If you cannot find an answer to a question in the FAQs, you can send an e-mail to enquiries@rbo.gov.ie.