Beneficial ownership and annual returns: keeping your company in good standing

Over the past two years, the Registrar of Companies has issued notices requiring companies to file their beneficial ownership information. One notice in October 2024 gave companies 30 days to comply, and another in April 2025 gave a further 30 days after the first deadline passed.

What the law requires

  • Every company must keep a register of its beneficial owners, the people who ultimately own or control it, and lodge it with the Registrar. This comes from section 93A of the Companies Act, 2015 and the Companies (Beneficial Ownership Information) Regulations, 2020.
  • The register must be kept up to date when ownership or control changes.
  • Companies must also file an annual return with the Business Registration Service every year.

Why it matters to you

Banks, landlords and tender committees increasingly ask for a recent CR12 and proof that filings are up to date. A company that is behind on its returns can struggle to open accounts, win tenders or complete a sale, and in the worst case the Registrar can strike it off the register.

A quick health check

  • Can you download a current CR12 that shows the right directors and shareholders?
  • Has your beneficial ownership information been lodged, and does it reflect any changes since then?
  • Are your annual returns filed for every year since incorporation?
  • Do your board and shareholder minutes record the decisions behind any changes?

If the answer to any of these is no or not sure, our company secretarial team can bring your records up to date.

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