From 1 June 2017, a number of changes will be enforced by the CROs office in relation to mandatory return filing, financial statements and fees which will apply to all Irish companies.

 

Mandatory electronic filing

The CRO will require mandatory electronic filing for the following documents in accordance with S.I. No. 458 of 2016 and Section 897, Companies Act 2014:

  • B1 – Annual Return (including financial statements and electronic payment – see changes below)
  • B2 – Change of registered office (Change: From 1 June can no longer be filed on paper)
  • B10 – Change of director and/or secretary, or a change in their particulars (Change: From 1 June can no longer be filed on paper)
  • B73 – Nomination of a new annual return date (Change: Can no longer be filed on paper)

 

The major benefits of e-filing these documents are:

  • There is no fee for filing Forms B2, B10 and B73 electronically.
  • The fee for filing an e-B1 is €20 compared with the current €40 fee for filing a paper B1.
  • Errors on documents are minimised as the user is alerted if any information they enter is inconsistent with the information already held on CRO’s records for that company.
  • Registration is faster and more efficient.
  • The amount of paper to be printed and posted to the CRO is reduced to one page in most cases or no pages at all if ROS (Revenue Online Service) certificates are used. 

 

Changes to filing Form B1 after 1 June 

From 1 June 2017, the sole means of filing a B1 and financial accounts and paying for an annual return will be in electronic form. However, the signature page must still be printed off, signed and submitted manually to the CRO (unless digitally signed using ROS).

For anyone who has filed B1’s electronically in the past, the main changes from 1 June are outlined below. 


PDF of Financial Statements:

  • all financial statements MUST be uploaded as a PDF attachment on CORE/software package within 28 days of the date the e-B1 was submitted. Hard copies of the financial statements will not be accepted by the CRO after 1 June. 
  • the PDF of the financial statements can be attached to the e-B1 in your Workspace in CORE/ software package, in much the same way as you attach a document to an e-mail. 
  • the B1 signature page must not be delivered to the CRO until AFTER the financial statements have been uploaded as a PDF. Please note that the signature page will be returned by the CRO if the financial statements have not been uploaded on receipt. 

 

Electronic Payment:

  • the filing fee and any late filing penalties MUST be paid electronically by credit /debit card or by CRO Customer Account. You will not be able to complete the submission of the e-B1 without first making the payment at the submission stage. 
  • It will not be possible to pay the filing fee of €20 and/or any late penalties by cheque, postal order, money order or bank draft. However, it will continue to be possible to top-up a Customer Account by cheque etc. after 1 June. 

 

Filing a form electronically for the first time 

All forms can be filed electronically using CRO’s online filing system CORE https://core.cro.ie/ or through a secretarial software package. 

To file electronically on CORE you must first register as a new user. Once you are registered you can log in and go to “File a Form”, select your submission (e.g. B1) and complete the form. There are links on CORE to help you if you encounter any difficulties when filing online. 
 
Signing a B1 form filed electronically 

When filing the B1 form the company has three options for signing the form. The option chosen will dictate what, if any, additional documents must be delivered to the CRO. 

B1 Signing Options Required to be delivered to the CRO

 

  1. Manual Signing

 

  • The signature page must be printed and signed by a Director and Secretary. The signature page must then be sent to the CRO, O’Brien Road, Carlow. 
  • The submission is not complete until the manual signature page is received in the CRO.

 

  1. Digital signature by agent

 

  • The company’s Electronic Filing Agent signs digitally using ROS Certificate (Revenue Online Service). There are two pages to sign:
  1. a Patch Page (provided by CORE/software package) to be delivered with 
  2. an Overall Certification for the uploaded financial statements signed by a Director and Secretary

 

  1. Digital signature by director or secretary

 

  • A Director and Secretary sign the B1 digitally with ROS Certificates (Revenue Online Service). In this scenario there is no paper as everything is fully electronic and nothing is required to be physically delivered to the CRO 

 

Signatures on Financial Statements 

 

Financial statements presented to the CRO do not need to carry the manuscript signatures of Directors or Auditors. Instead, financial statements filed with the CRO must contain: 

  • The typed name(s) of the Director(s) who signed the financial statements on behalf of the Board of Directors;
  • The typed name of the Auditor (where applicable); and
  • The date each document was signed on. 

 

Important points to note when filing a B1 form: 

 

  • Once an e-B1 is submitted online not later than 28 days after the ARD, the company has a further 28 days to either digitally sign the B1 (in which case no paperwork may need to be delivered to the CRO) or manually sign and deliver the signature page to the CRO.
  • If the B1 signature page is not printed, signed and delivered to the CRO within 28 days of the B1 being submitting online, the annual return will be late and the company will incur late penalties and lose audit exemption in the current year and in the following year. 
  • Financial Statements must be uploaded as a PDF no later than the end of the second 28 days and before the signature page is delivered to the CRO.