Green shoots on protecting Directors’ residential details from public access Consultation on reforms to disclosure under the Companies Act 2014

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. 

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