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🔍 Beneficial ownership — AML compliance

RBO Filing Ireland.
Both Duties. Done Right.

Irish companies have two separate beneficial ownership obligations — maintain the internal register and file matching details with the central RBO. Completing one does not replace the other. Forti handles both.

Check my RBO status →
Initial filing due within five months of incorporation.
Changes must be reported within 14 days of the internal register update.
RBO — key facts at a glance
Deadlines
Initial filing after incorporation
Within 5 months
Ownership or detail changes
Within 14 days
Annual RBO return
No annual return
Threshold and identity
Ownership threshold
More than 25%
No Irish PPSN — use Form VIF
Guided
In-person VIF witnessing (from Apr 2026)
Required
Pricing
Standalone RBO registration
€150 + VAT
CRO government filing fee
None
Check my RBO status →
📅
Initial deadline
Within 5 months of incorporation
🔄
Change deadline
Within 14 days of internal register update
💶
Standalone fee
€150 + VAT — no CRO government fee
📍
Based in
Sandyford, Dublin 18

This service is for you if

You have incorporated an Irish company and have not yet completed the initial RBO filing
Shares, voting rights, control or a beneficial owner's personal details have changed
You are not sure who qualifies as the ultimate beneficial owner
No individual appears to own more than 25% and you need guidance on the senior managing official fallback
A beneficial owner does not have an Irish PPSN and needs Form VIF / IPN guidance
A bank, accountant or solicitor has flagged a mismatch in the beneficial ownership records
The company filed centrally with the RBO but never created or updated its internal register

Two separate beneficial ownership duties

Completing one does not replace the other. The internal register and the central RBO filing must contain matching, current information.

1
Maintain the internal register
The company must identify its beneficial owners, keep their required details current and record the steps taken to establish who ultimately owns or controls the company. This register is held by the company — not submitted to the RBO portal.
2
File matching details with the RBO
The central filing is completed online through the RBO portal. It is separate from CRO forms, the Form B1 Annual Return and the statutory register of members. The information must match what is held on the internal register.
The RBO and the CRO Annual Return are entirely separate obligations with different systems and different deadlines. Filing Form B1 does not complete the RBO obligation.

Who counts as a beneficial owner

A beneficial owner must be a natural person. The review follows the ownership chain until it identifies the people who ultimately own or control the company. A shareholder is not automatically the only beneficial owner.

📊
Direct share ownership
A person who owns more than 25% of the company's shares, directly. Note: the legal threshold is more than 25% — not 25% or more.
🗳️
Voting control
A person who controls more than 25% of the voting rights, directly or indirectly — including through parent entities or voting arrangements.
🔗
Control through other means
This can include a shareholders' agreement, dominant influence or the power to appoint or remove senior management.
👔
Senior managing official fallback
If all possible means have been exhausted and no natural person is identified, the company records the relevant senior managing officials and keeps evidence of the review steps taken.

What the RBO filing records

The first name and surname must match the Department of Social Protection record linked to the PPSN. A mismatch can cause the submission to be rejected.

🪪
Identity details
Legal first name and surname, date of birth, nationality, country of residence and residential address.
📊
Ownership or control
The nature and extent of the interest held or control exercised, including the relevant percentage or control route.
🔢
Dates and identifier
Date entered as a beneficial owner, any cessation date and the person's PPSN or IPN.
The name entered in the RBO must exactly match the Department of Social Protection record linked to the PPSN. A mismatch — even a minor spelling difference — can cause the submission to be rejected by the portal.

Beneficial owners without an Irish PPSN

A beneficial owner who does not have an Irish PPSN must use Form VIF (Verification of Identity Form) to obtain an Identified Person Number (IPN). The IPN can normally be reused for that person's future CRO and RBO filings.

Since 30 April 2026, the CRO only accepts VIF forms where the declarant and witness were physically in the same room when signing. Online or video witnessing is not accepted.
The current VIF form must be used. Older VIF versions received after the change are rejected by the CRO.
One successful VIF is normally enough for that individual — the IPN can be reused for future CRO and RBO filings.
The name, date of birth, nationality and residential address on the VIF must be accurate and consistent with later filings.
An IPN must not be requested where the person already has an Irish PPSN — the PPSN must be used instead.
Form VIF replaced BEN2. References to BEN2 as the current form name are outdated.
🔗
Non-EEA resident directors
A non-resident founder may also need a Section 137 Bond and director identity verification alongside the RBO work.
View non-EEA resident director service →
🏢
Setting up an Irish company
Forti can coordinate incorporation, RBO filing, tax registration and the first compliance deadlines together.
View company registration →

Why banks and other advisers check the RBO

Banks, accountants, auditors and solicitors must check that beneficial ownership information has been entered in the RBO before establishing a business relationship.

🏦
Bank account access can be delayed
A bank can open an account before completing the RBO check, but cannot allow transactions through the account until beneficial ownership is confirmed. A missing or mismatched filing can therefore block access.
📋
Discrepancies must be reported
Designated persons must report material discrepancies or non-compliance to the Registrar. The RBO filing, internal register and onboarding documents should all tell the same ownership story.

How Forti handles your RBO filing

1
Beneficial ownership review
We review the shareholding, voting rights, parent entities, shareholder agreements and other control arrangements to identify the correct beneficial owners.
2
Identity and deadline check
We confirm each beneficial owner's legal details, PPSN or IPN position, and the date the filing or update is due.
3
Internal register preparation
We create or update the company's internal beneficial ownership register and record the basis used to identify the individuals listed.
4
Central RBO filing
We prepare and submit the online filing through the RBO portal and retain the confirmation for the company's records.
5
Ongoing changes
Where Forti provides company secretarial support, ownership and control changes are tracked alongside the related CRO and statutory-register updates.

What is included

Review of direct and indirect ownership and control
Identification of beneficial owners or senior managing officials
Preparation or update of the internal beneficial ownership register
Electronic RBO filing and submission confirmation
Form VIF and IPN guidance for owners without a PPSN
Correction of straightforward ownership or identity mismatches
Coordination with share transfers, allotments and company secretarial records

RBO filing pricing

The RBO does not charge a government filing fee. Forti's fee covers the review, preparation and submission work. All fees exclude VAT.

Most common
Standalone RBO Registration
Initial filing or standard ownership update
€150
+ VAT · No CRO government fee
Get started
Annual Company Secretarial
Statutory registers, RBO updates and ongoing company secretarial support
€450
+ VAT / year
View pricing

Complex ownership chains, historic corrections and VIF-related work may require a separate quote. Forti confirms scope and fee before work begins.

Get an exact RBO quote

Send the company number and a summary of the ownership structure. We will confirm what is required and the fee before work starts.

Check my RBO status →

RBO problems that need attention

Assuming the Form B1 covers the RBO
The CRO Annual Return and RBO filing are entirely separate obligations with different systems, portals and deadlines.
Treating 25% as an automatic cut-off
The legal threshold is more than 25%. Indirect ownership, voting control and control through other means must also be considered.
Waiting until the next annual filing to report a change
RBO changes must be reported within 14 days of the change to the internal beneficial ownership register — not at an annual return date.
Using BEN2 as the current form name
The current form is Form VIF. BEN2 is a legacy name no longer in active use. Older form versions received after the rule change are rejected.
Mismatched personal details in the portal
Names, dates of birth, PPSNs and IPNs must match the official identity records. Even a minor spelling difference can cause a rejection.
Filing centrally but ignoring the internal register
The company must maintain its own current beneficial ownership records and evidence of the steps taken to identify the owners.
Failure to file or maintain correct beneficial ownership information is a criminal compliance issue. Knowingly or recklessly filing materially false information can lead to a Class A fine or imprisonment on summary conviction, or a fine of up to €500,000 and imprisonment on indictment.

Related Forti services

Company secretarial
RBO updates, statutory registers, board minutes and CRO filings managed together.
View company secretarial →
Annual compliance
B1 Annual Return, accounts and other compliance deadlines coordinated.
View annual compliance →
Company registration
Formation packages that include company documents and initial compliance support.
View company registration →
Non-EEA resident director
Section 137 Bond and identity support for founders outside the EEA.
View non-resident director support →
Limited company accounting
Bookkeeping, VAT, annual accounts and Corporation Tax support after formation.
View company accounting →
Forti pricing
Compare current standalone and ongoing company compliance fees.
View all pricing →

Common questions about RBO filing

What is the RBO in Ireland?
The RBO is the central Register of Beneficial Ownership for Irish companies and industrial and provident societies. It records the natural people who ultimately own or control the entity.
Is RBO filing the same as the CRO Annual Return?
No. The RBO is a separate register established under anti-money laundering rules. Filing Form B1 with the CRO does not complete the RBO obligation.
When is the first RBO filing due?
A newly incorporated company must file its beneficial ownership details within five months of incorporation.
How quickly must an ownership change be reported?
The RBO must be updated within 14 days of the change to the company's internal beneficial ownership register.
Is there an annual RBO return?
No. You file after incorporation and whenever the beneficial ownership information changes. The internal register must be kept current at all times.
Who is a beneficial owner?
A beneficial owner is a natural person who ultimately owns or controls the company. This includes ownership of more than 25% of shares, control of more than 25% of voting rights, or control through other means such as shareholder agreements or dominant influence.
What happens if nobody owns more than 25%?
The company must review indirect ownership and other forms of control. If all possible means are exhausted and no natural person is identified, the relevant senior managing officials are recorded and the company keeps evidence of the steps taken.
What if the beneficial owner has no Irish PPSN?
They use Form VIF to obtain an IPN. The IPN can normally be reused for that person's future CRO and RBO filings.
Can a VIF be witnessed over video?
No. From 30 April 2026, the CRO only accepts VIF forms where the declarant and witness were physically in the same room when signing.
Can a missing RBO filing delay a bank account?
Yes. Banks must check that beneficial ownership information is entered in the RBO. A bank may open an account before the check, but transactions cannot proceed until the information is confirmed.
Can the public see all beneficial owner details?
No. General public access is limited. Competent authorities and approved designated persons have wider access for regulatory and customer due diligence purposes.
Do dormant companies need to file with the RBO?
Yes. The obligation applies to Irish companies within scope even where they are dormant or have not started trading.
Who is responsible if an accountant files for the company?
The directors, secretary and company remain responsible for accuracy and timing. An accountant can act as presenter, but that does not transfer the statutory responsibility.
How much does Forti charge for RBO registration?
Forti's standalone RBO registration fee is €150 + VAT. There is no government filing fee for the RBO. Ongoing company secretarial support is available separately.

Keep the RBO and
company records aligned.

The filing should match the ownership structure, the internal register and the information provided during banking and AML checks. Forti reviews all three before submitting or correcting the record.

Check my RBO status →
€150 + VAT standalone No CRO government fee Response within one business day

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  • Unit 106, Nesta Business Centre, 4-5 Burton Hall Rd, Sandyford, Dublin 18, D18 A094, Ireland

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