Information on Beneficial Ownership
A beneficial owner is any person who owns or controls at least 25% of voting rights or shares in a company, either directly or indirectly. In charities, typically Companies Limited by Guarantee (CLGs), this refers to those with significant control, like trustees.
Who are a Charity’s Beneficial Owners?
Beneficial owners usually include your Senior Managing Officials, like trustees and the CEO (or equivalent).
The RBO is a central database that holds required information about who owns or controls Irish companies. It includes details about the real people behind these organisations and their ownership or control.
Irish Anti-Money Laundering (AML) Regulations 2019 require companies to:
Keep an internal beneficial ownership register
File details of beneficial owners with the RBO, managed by the Companies Registration Office (CRO).
Charities that are also Companies Limited by Guarantee (CLGs)
Charities in other company formats, unless exempt
Other entities registered in Ireland with the CRO.
There is a separate register for Trusts. More information is on this page.
Charities must collect and submit these details for each beneficial owner for the RBO and their internal register:
Full name
Date of birth
Address
Nationality
Country of residence
Date of commencement as Beneficial Owner (when the trustee joined the board or became CEO)
PPS number for verification. If you lack a PPSN, apply for an Identified Person Number (IPN) with the CRO.
These details are not publicly available on the RBO. When someone looks up an organisation’s beneficial owners, they’ll typically see only initials and the year of birth.
Important note: This also applies when accessing your own organisation’s information on the RBO. That’s why maintaining an internal register is crucial.
Some entities do have access to RBO details:
A Discrepancy Notice is issued when someone finds that RBO information might be incorrect or incomplete. This can be submitted by designated persons from Tier One or Tier Two entities.
If you receive a Discrepancy Notice, it indicates a potential issue with your RBO filing. For example, if you’re opening a new bank account and the beneficial owners’ details don’t match the RBO, you’ll likely get a notice.
This doesn’t mean your organisation did something wrong, but you should check your internal register and RBO filings to ensure they match and are up-to-date. The notice allows you to correct any errors.
Recent updates to the European AML regulations require Trusts to maintain an internal register of their Beneficial Ownership and file details with the central register operated by Revenue .
We’ve worked closely with Revenue to understand what this means for charities. They’ve published
Frequently Asked Questionsas guidance, including a section for charities. This area can be complex.
You may need legal advice or reach out to Revenue directly at [email protected] for queries.
Find out how you can cut your costs, and maybe even avail of FREE membership, by joining The Wheel today.