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The Department of Enterprise Tourism & Employment are currently considering proposed changes to the Companies Act 2014 which if implemented would protect a Director's residential address being publicly available. Here we consider the proposed changes and the implications for Directors.
Directors may be able to decide to keep their residential address private if the recommendations of the Company Law Review Group are implemented into Law. Proposed amendments to the Companies Act 2014 (the Act) would replace public disclosure of directors' and secretaries' usual residential address with a "contact address". The Department of Enterprise, Tourism and Employment (DETE), is currently consulting these changes, with submissions requested by 19 December 2025.Directors will welcome such developments which would address privacy and personal safety concerns that are linked with a directors' usual residential address being publicly available in the Companies Registration Office (CRO).
Since 11 June 2023, directors must provide their Personal Public Service Number (PPSN) when submitting certain forms to the CRO. However, once validated, the PPS number is stored by the CRO in an irreversible encrypted format, ensuring it is secure, inaccessible to CRO staff or third parties, and never shared externally and so the non-publication of information is not new to the CRO.
Background
Under Section 149 of the Act, a company must keep a Register of Directors and Secretaries (the Register) that includes each officer's usual residential address. This address is also filed in certain documents with the CRO and is publicly available on the CRO register. Any changes to the address are also required to be notified to the CRO.
Under Section 216 of the Act, the Register must be available for inspection in person during business hours to any member of the company and any other person for a fee. The requirement to include a usual residential address facilitates the identification of an officer and also facilitates direct communication with them.
Recommendations / Proposed Changes
It is proposed that:
- Directors and individual secretaries could provide a "contact address" for the purposes of access by the public instead of their residential address.
- The contact address may be a director's / secretary's residential address, the company's registered office, or another address prescribed by the Minister.
- The address must be in the State.
- The chosen "contact address" would be the only address available to the public on the Company's Register of Directors and Secretaries (and Register of Members where applicable) and on the CRO Register.
- While Companies and the CRO would continue to hold the usual residential address, access would be restricted to entities prescribed by the Minister.
- The changes would not be retrospective. Residential addresses already on historic CRO filings would remain visible on those prior records
- For more information on proposed changes to the Companies Act 2014 and related legislation, please see: Public consultation on proposed changes to the Companies Act 2014 and related legislation
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
