Creation of Central Register of Beneficial Ownership Postponed until Q1 2018

By Andrew Lambe, 12th June 2017 (Updated 19th October 2017)

We have recently learned that The Department of Finance has postponed the implementation of the Central Register of Beneficial Ownership until Q1 2018 at the earliest. This was the second and final part of Ireland’s implementation of the 4th EU AML Directive (AML4D) with the first part being the creation of an internal register of beneficial ownership that the vast majority of limited companies and their directors are obliged to create and maintain since 15th November 2016. Another interesting development is that Irish based beneficial owners will most likely be required to detail their PPS number as well as other basic details. Non-residents will be required to detail their passport number, and possibly upload a scanned copy of their passport.

The reason it is being delayed is to do with high-level discussions around the proposed 5th EU AML Directive (AML5D). These discussions and considerations will have an impact on the legislative drafting process and according to the Department of Finance, means that the original 4AMLD transposition date of 26th June 2017 is no longer feasible. Our latest information is that this central register of beneficial ownership, when implemented, will only be accessible by tax authorities and designated government bodies. However, the Scandinavian countries are pushing to have the register fully accessible by members of the public as part of AML5D discussions.

When the final part of AML4D is finally implemented, it is expected companies will have 6 months to file details of ultimate beneficial owners with the Central Registry. All companies must comply as well as ICAV’s, Trust and Societies. LP’s would appear to be exempt as things currently stand.

It is important to remember that all companies currently have a requirement to maintain an internal register of beneficial owners. For more information or assistance on creating and maintaining your register of ultimate beneficial owners, please don’t hesitate to contact a member of our cosec team on +353 1 6461625 or email us at


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