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Ireland is on course for its most active year of company incorporations on record. At the Chartered Institute of Governance UK & Ireland conference in Dublin last week, the Companies Registration Office (CRO) confirmed that 2025 delivered over 25,000 new incorporations - and 2026 is tracking towards 30,000, with a 30% uplift in Q1 alone. By any measure, Ireland's appeal as a jurisdiction is not dimming.

But there is a tension at the heart of this growth story that boards, company secretaries, and legal advisers should not gloss over: the sheer volume of submissions arriving at the CRO contains an overwhelming proportion of errors. The consequence is re-work, delays, and in many cases full resubmission. For any business with time-sensitive structuring or funding needs, that is a material operational risk; and it is largely avoidable.

Why are so many submissions wrong?

Several factors converge. The CRO's digitalisation programme is well advanced, with 96% of submissions are now electronic; but the ecosystem around it has not always kept pace. Agents, presenters, and clients alike sometimes work from outdated assumptions about what the system requires. Some elements of the underlying legislation are genuinely archaic: signature requirements that predate the internet are not being consistently applied, and the CRO itself acknowledged this openly at the conference.

The more structurally important shift is on director identity. Ireland's PPSN requirement, introduced under the Companies (Corporate Enforcement Authority) Act 2021, has transformed the onboarding process for non-resident directors. Where an Irish-resident director supplies a PPSN cross-referenced against Department of Social Protection records, a non-resident must obtain a Verified Identity Number (VIN) via a Form VIF: a formal declaration witnessed by a notary, physically signed, and uploaded to CORE. A previous route that allowed some directors to sidestep this process was being exploited at scale, and the CRO has moved to close it firmly.

The practical implication: non-resident directors can no longer be treated as an afterthought in an incorporation timeline. VIN applications need to be initiated early, notarisation takes time, and exact name and date-of-birth matching between the VIF and CRO records is non-negotiable. A single discrepancy will result in rejection.

Enforcement is returning, including UBO

The conference also surfaced a topic that many in the compliance community will have been monitoring quietly: the planned resumption of CRO enforcement action after the Covid-era suspension. The CRO was refreshingly candid, Enforcement against non-filing directors and, notably, liquidators who have deprioritised filing obligations as a commercial decision, will recommence in the near term. Correspondence will precede prosecution, but the CRO is actively scoping which cases to pursue first.

Beneficial ownership (UBO) non-compliance sits alongside this. Discrepancy notices have already been issued, and the CRO is shifting from a posture of gentle encouragement to active enforcement. Under the Companies Act 2024, new involuntary strike-off grounds for RBO non-compliance came into effect in July 2025. For companies managing multiple entities, this is the moment to audit UBO accuracy - not wait for a notice to arrive. Those with complex or cross-border ownership structures could be the most exposed.

What this means in practice

For governance professionals managing Irish entity portfolios, the message from the CRO is consistent: accuracy and preparation pay dividends.

  • Audit director information held at the CRO against DSP records before annual return season
  • Build VIN/VIF timelines into incorporation project plans for any non-resident director
  • Ensure UBO registers are current, accurate, and reconciled with CRO-held data
  • Flag entities with outstanding liquidator filings before enforcement correspondence arrives

The growth in Ireland as a domicile of choice is excellent news. But volume creates pressure, and pressure creates errors. Companies that invest in disciplined entity management now will avoid the compliance drag that is clearly building in the system.

Law Debenture provides entity management and corporate secretarial services across Ireland and 120+ jurisdictions globally. To discuss how we support corporate compliance programmes in Ireland, please get in touch.

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