In Ireland the right to search the Register of Beneficial Ownership (RBO) belongs to your firm, not to your software. As a designated person applying customer due diligence, you have a right of access to each beneficial owner’s name, month and year of birth, nationality and country of residence, and to the nature and extent of the interest or control they hold. The register alone is not enough to discharge the duty, so the client file has to show what you found, where, when, and what you did beyond it.
- Who may search the RBO today
- What a designated person receives from the register
- Why the register alone is not enough
- What the client file must show afterwards
- Why no software can search the RBO for you
- A record you can copy
- FAQ
Who may search the RBO today
Irish designated persons taking customer due diligence measures have a right of access to the RBO in a timely manner. Competent authorities and certain public bodies retain access for their functions. Other people must first demonstrate a legitimate interest to the Registrar under the amended access rules; general public access is no longer available simply because someone wishes to search.
Access now falls into three groups. Regulation 25(1) of the 2019 Regulations covers designated persons taking CDD measures. Competent authorities and certain public bodies keep access connected with their statutory work. Everyone else must satisfy the legitimate-interest test introduced by the 2023 amending Regulations.
The change followed the Court of Justice of the European Union judgment in joined cases C-37/20 and C-601/20 on 22 November 2022. The judgment invalidated unrestricted public access to beneficial ownership information. Under the new regulation 25(3A), anyone else must show the Registrar three things: that they are engaged in preventing, detecting or investigating money laundering or terrorist financing; that the search is for that work; and that the company is connected with people convicted of such offences or holds assets in a high-risk third country.
The legitimate-interest route is narrow and does not replace your own access. A designated person carrying out CDD for a client relies on regulation 25(1), not on regulation 25(3A).
What a designated person receives from the register
A designated person receives limited beneficial ownership information from the RBO, not a complete identity file. The register can show each beneficial owner’s name, month and year of birth, country of residence, nationality, and the nature and extent of the interest or control. It does not provide a full date of birth or address.
| RBO information | What it tells you | What the client file should do |
|---|---|---|
| Name | The registered beneficial owner’s name | Record the result and compare it with client information |
| Month and year of birth | A limited identity detail | Use it as part of identity verification |
| Country of residence | The registered residence country | Consider it in the risk assessment |
| Nationality | The registered nationality | Compare it with available evidence |
| Nature and extent of interest or control | How the person owns or controls the entity | Explain the ownership and control structure in the file |
Where the beneficial owner is a minor, the access process has an additional public-interest safeguard. The Registrar requires a written summary explaining why disclosure is in the public interest and will refuse access unless satisfied on that point.
A firm seeking designated-person administrative access applies to the RBO using Form BEN3A1, identified in A&L Goodbody’s explanation of the Irish access rules.
Why the register alone is not enough
An RBO extract is one source for customer due diligence, not the whole CDD exercise. The Irish rules say register information must not be relied on exclusively. Your file must show risk-based verification of the beneficial owner and an understanding of the customer’s ownership and control structure.
Regulation 25(2) states that information obtained from the register must not be relied on exclusively. The wider CDD requirement is set out in section 33(2)(b) of the Criminal Justice (Money Laundering and Terrorist Financing) Act. That provision requires measures warranted by the risk to establish who the beneficial owner is and to understand the structure.
In practice, the RBO extract should sit alongside evidence from the client and other relevant sources. Your record should explain what you verified, which document supported the verification, and why the evidence gave you reasonable grounds to be satisfied about the beneficial owner.
If the beneficial owner is the senior managing official, record the measures used to verify that person’s identity. Also record any difficulties encountered. The point is not to create a longer file for its own sake. It is to make the firm’s reasoning visible to a reviewer.
For a practical approach, keep the AML client risk assessment record connected to the ownership evidence.
What the client file must show afterwards
An inspector reading the file should be able to distinguish the firm’s own findings from information supplied by a register or vendor. The record should show when the firm searched the RBO, what it found, how the information was verified, how the ownership structure was understood, and who reviewed the conclusion.
Use this as a file checklist:
- Who searched the RBO, in the firm’s own designated-person account, and the date.
- The RBO result, including whether it identified a beneficial owner or held no relevant person.
- The extract or other record retained from the search.
- The documents used to verify the beneficial owner and the identity details checked against them.
- A plain-language description of the ownership and control structure, including any holding company.
- Any difference between the RBO and the firm’s documents, together with the action taken to investigate it.
- The steps taken and any difficulties encountered where the senior managing official is recorded.
- The client risk rating and the reasons supporting it.
- The reviewer’s name or role and the review date.
Do not present a vendor-generated note as if it were the firm’s own RBO finding. Keep the source, date and responsible party visible. That separation creates a clearer audit trail and shows which conclusions came from official registries, which came from client evidence, and which were made by the firm.
Why no software can search the RBO for you
The access right belongs to the designated person taking CDD measures, and the RBO does not offer programmatic access. A monitoring service therefore cannot watch Irish beneficial owners for you. Treat any promise of Irish RBO ownership alerts carefully and ask which official source produced the information.
For an Irish client, EntityWatch reads the Companies Registration Office for company status, insolvency and registered address. It screens the company and named persons against sanctions and PEP lists, then writes a due diligence note with its sources. The note states why beneficial owners were not read from the RBO.
Your firm can add what it found in the RBO in its own name, with the source and date of the search. EntityWatch stores that addition in the same client file, while keeping your RBO finding separate from the registry and screening information it supplied. See the published EntityWatch coverage for the countries and sources covered.
EntityWatch does not read the Irish RBO, monitor Irish beneficial owners or monitor Irish directors. It does not declare a company sanctioned. A possible sanctions or PEP match is routed to your review and is never recorded as a confirmed hit, so the decision remains with your firm.
A record you can copy
Use a short, source-labelled note that records both the RBO search and the wider CDD work. The template below is designed to make the point-in-time check, evidence, reasoning and review visible without presenting the RBO as the sole basis for the conclusion.
Client:
CRO number:
Date of RBO search:
Person carrying out the search:
RBO result:
- Beneficial owner named, or no relevant person shown:
- Information recorded from the RBO:
- Extract or search record retained at:
Verification:
- Client documents reviewed:
- Identity details checked against each document:
- Other relevant evidence considered:
Ownership and control:
- Plain-language description of the structure:
- Holding companies or intermediate entities:
- Senior managing official, if applicable:
- Verification steps and difficulties, if applicable:
Differences and follow-up:
- Difference between RBO information and client evidence:
- Action taken to investigate:
Risk assessment:
- Risk rating:
- Reasons:
Review:
- Reviewer:
- Review date:
- Decision and next action:Keep the completed record with the RBO extract, the client evidence and the firm’s risk assessment. If you use EntityWatch, add the firm’s own RBO findings to the note with the source and date, and retain the registry-sourced information separately. This gives the file a clear audit trail without claiming that software accessed the RBO.
You can also compare this record with EntityWatch’s guidance on what counts as evidence in ongoing client monitoring. The same principle applies: record the source, the point in time, the finding and the action taken.
FAQ
The short answer is that designated persons retain access for CDD, but the RBO is only one part of the file. Public access is restricted, software cannot search the RBO programmatically, and your firm must record its own findings and risk-based verification.
Can a member of the public still search Ireland’s RBO?
Only after demonstrating a legitimate interest to the Registrar under regulation 25(3A), inserted by S.I. No. 308/2023 after the CJEU judgment. The person must fall within the circumstances set out in the amended Irish rules. General public access is not available merely because the information is of interest.
Can my software provider search the RBO on my behalf?
The access right in regulation 25(1) belongs to the designated person taking CDD measures. The RBO has no programmatic access. A provider cannot therefore monitor Irish beneficial owners through an automated RBO connection. Keep your own search record and distinguish it from vendor-supplied information.
Is an RBO extract enough for customer due diligence?
No. Regulation 25(2) says the register must not be relied on exclusively. Section 33(2)(b) of the Criminal Justice (Money Laundering and Terrorist Financing) Act requires verification warranted by the risk and an understanding of the ownership and control structure.
What does the RBO show about each beneficial owner?
It shows the name, month and year of birth, country of residence, nationality, and the nature and extent of the interest or control. It does not show a full date of birth or address. Retain the extract and explain how the details were verified.
What if the beneficial owner is a minor?
The Registrar asks for a written summary explaining why disclosure is in the public interest. Access is refused unless the Registrar is satisfied on that point. Record the outcome and any relevant evidence in the client file.
Write your first Irish client note free
Enter a CRO number in EntityWatch. EntityWatch reads the Companies Registration Office, screens sanctions and PEP lists, and writes the due diligence note with its sources. Add what your firm found in the RBO, with the date, and approve the file. It is free for up to five companies.
General information, not legal advice.
This content was generated with artificial intelligence.