Diarmaid Gavin and Scion Flanagan

The Department of Enterprise, Tourism and Employment (DETE) is considering responses to a public consultation on proposed amendments to the Companies Act 2014.

The consultation, which closed on 19 December 2025, sought stakeholder views following a September 2025 report from the Company Law Review Group (CLRG) which proposed that the 2014 Act be amended to enable company officers to provide a ‘contact address’ in place of their ‘usual residential address’ for the purpose of various Companies Registration Office (CRO) filings and company statutory registers.

The consultation also sought stakeholder input on similar approaches proposed for co-operative societies, limited or general partners in limited partnerships and individuals applying to register business names.

Current position

Section 149(1) of the 2014 Act provides that companies must maintain a register of directors and secretaries, containing the usual residential address of each officer.

Section 216(9) of the 2014 Act provides that the register must be available for in-person inspection during business hours by any member of the public for a fee.

Further, company officers are required to detail their usual residential address on various CRO filings, including on their appointment or removal as company officers.

The company officer’s usual residential address is therefore publicly available, which both helps them to be identified or contacted and raises legitimate questions regarding privacy.

Pursuant to the Companies Act (Section 150) (No. 2) Regulations 2015, company officers can apply to withhold their usual residential address from filings on personal security grounds.

The application process involves submitting a Form T1 and an accompanying statement from a member of An Garda Síochána with the rank of Chief Superintendent or above.

If the exemption is granted, the company officer is permitted to enter the company’s registered office in place of their usual residential address.

The 2015 Regulations do not apply retrospectively meaning prior filings containing the company officer’s usual residential address remain publicly available.

Proposed changes

The CLRG has proposed that company officers should be able to provide a contact address for the purpose of public company records and filings instead of their usual residential address. The address would need to be in the State and be suitable for the service of documents.

The CRO would still hold the company officer’s usual residential address, which would be publicly available on foot of a court order or to prescribed authorities which includes, among others, An Garda Síochána, the Revenue Commissioners and the Central Bank of Ireland.

It is proposed that such changes would not apply retrospectively and instead a point in time would be selected from which they will apply, meaning prior filings containing the usual residential address of officers would be unaffected.

The proposals also recommend repeal of the 2015 Regulations.

Retrospective application

Retrospective application is not contemplated by the proposals. Significant resourcing would understandably be required to retrospectively redact usual residential addresses of company officers or to replace each with a contact address.

In the UK, an application-based redaction mechanism exists pursuant to which company officers can seek the redaction of residential addresses from historic filings for a fee and which requires them to list the documents where redaction is sought.

Furthermore, developments in artificial intelligence might ease the administrative burden associated with applying the proposed changes retrospectively.

Outlook

The DETE is considering responses to the consultation and it is anticipated that reforms will be introduced during the course of 2026.

In many instances, existing company officers will not benefit from the proposals as currently drafted as their usual residential address will remain publicly available.

The consultation received stakeholder feedback supporting the proposals in circumstances where the current requirement to disclose usual residential addresses is a potential deterrent to foreign direct investment.

However, the proposals have attracted criticism from certain sectors of the media who have raised concerns regarding the potential implications for corporate investigative journalism.

The approach in the UK has to some extent moved to address the cost and administration burden associated with retrospective redaction and it will be intriguing to see whether any reforms in Ireland will follow suit.

Should the proposals be adopted, companies will be required to maintain an internal register of officers’ usual residential addresses and a publicly available register containing contact addresses.

Diarmaid Gavin is a partner and Scion Flanagan is a solicitor at RDJ LLP.