The Chartered Governance Institute - Republic of Ireland Region (formerly Institute of Chartered Secretaries and Administrators)

Total Lobbying Efforts: 6

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Lobbying Records (Page 1 of 1)

2021-09-08
Politician(s) lobbied: Maureen O’Sullivan (Registrar of Companies), Department of Business, Enterprise and Innovation
Intent: The removal of the requirement to include the residential address of a director on SAP declarations
Methods: Email
Details & Methods:
MethodDescription
Summary Approval Procedure (SAP) Declarations: Directors' Residential Address
2020-09-08
Politician(s) lobbied: Maureen O’Sullivan (Registrar of Companies), Department of Business, Enterprise and Innovation; John Newham (Assistant Secretary), Department of Business, Enterprise and Innovation
Intent: We recommended either that implementation be delayed to a quieter time, possibly December 2020 or the extension of time to file the 2020 annual return should be further extended to 31 December 2020. This extension would align with the emergency measures in the Companies (Miscellaneous Provisions) (COVID-19) Act 2020 to defer the holding of this year’s Annual General Meeting until 31 December 2020.
Methods: Email
Details & Methods:
MethodDescription
Letter outlining our concerns over the proposed Sept 2020 go-live date for the CRO Digital Transformation – updated online filing system. Because there was no published detailed timeline
all existing efiling forms would become obsolete and not be accepted by the CRO
autumn is the heaviest filing period for annual returns and
the need for software providers to provide timely upgrades for company secretarial practitioners – our members believed September was not the correct time to implement.
2020-05-11
Politician(s) lobbied: Maureen O’Sullivan (Registrar of Companies), Department of Business, Enterprise and Innovation
Intent: To ensure that the CRO would temporarily accept electronic copies of signatures on documentation during the period of the Covid-19 pandemic.
Methods: Email
Details & Methods:
MethodDescription
Request in writing
on behalf of the Institute's members in Ireland
to the Registrar of Companies to accept electronic copies of signed documentation rather than wet ink signatures
during the period of the Covid-19 Pandemic and the consequent closure of the CRO. This was to alleviate the undue burden on company secretarial members who were working remotely
of obtaining original signatures for documentation for subsequent filing at the CRO.
2020-01-08
Politician(s) lobbied: Gary Tobin (Assistant Secretary), Department of Finance; Doncha O’Sullivan (Assistant Secretary), Department of Justice and Equality; Breda Power (Assistant Secretary), Department of Business, Enterprise and Innovation
Intent: We offered recommendations to address the above include a proposed extension to the filing deadline.
Methods: Letter
Details & Methods:
MethodDescription
Issues relating to the online portal for the Register of beneficial ownership (established for the purposes of filing a company’s beneficial ownership details with the Registrar) including the reduced time for filing information
the lack of clarity on the process for submitting the Form BEN2
the absence of a facility to review and save draft submissions
concerns on the safeguarding of information keyed to the system and the absence of an exact reason when a submission is rejected.
2019-05-10
Politician(s) lobbied: Niall O'Ceallaigh (Human Resources / Corporate / Finance / I.C.T.), Department of Finance
Intent: If there is a requirement for a Director of an Irish company who is not an Irish resident and has not been allocated a PPS number, we are advocating that increased resources be allocated to the section within the Department of Social Welfare (DoSW) which issues PPS numbers. We anticipate that if there is a requirement for a Director of an Irish company who does not have a PPS number to apply for one, then there will be thousands of applications to this section of DoSW.
Methods: Letter
Details & Methods:
MethodDescription
European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 - Central Register of Beneficial Ownership
2019-01-21
Politician(s) lobbied: Breda Power (Assistant Secretary), Department of Business, Enterprise and Innovation
Intent: Improve the Companies Registration Office IT systems for public submission of documentation::Reduce administration regarding the filing of ultimate beneficial ownership information to include the facilitating of electronic upload of information::Remove requirement for directors who have an exemption from disclosing their residential address to provide a residential address for the Central Register of Beneficial Ownership::Remove the requirement to provide PPSNs to the Central Register of Beneficial Ownership::Remove criminal liability for presenters where incorrect information is provided to the Central Register of Beneficial Ownership
Methods: Letter
Details & Methods:
MethodDescription
Suggested improvements to CRO IT systems & Annual Return filing procedures
Central Register of Beneficial Ownership: proposal that Registrar should have enforcement measures for non-compliance
public register should mirror company's register
extend exemption to disclose residential address for directors who received this exemption
propose that parent co. be inserted on subsidiary register
not the board
exclude PPSNs
facilitate upoading electronically
no criminal liability for presenters