Ireland’s three beneficial-ownership registers: RBO, CRBOT and the Central Bank register

Ask most Irish designated persons about "the beneficial-ownership register" and they will name the RBO. That answer is only a third right. Ireland runs three separate beneficial-ownership registers, each covering a different type of entity, each operated by a different body. If your onboarding procedure only mentions the RBO, it has a gap — one that becomes more visible from 10 July 2027, when Regulation (EU) 2024/1624 (AMLR) replaces the substantive customer due diligence rulebook you currently follow under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.

Here is which register covers which client, what you must do with each, and how the EU package — the AMLR and Directive (EU) 2024/1640 (AMLD6) — changes the landscape.

The three registers at a glance

The practical point: the register you consult depends on what the client is, not on what sector you work in. An accountancy practice supervised by one of the designated accountancy bodies (Chartered Accountants Ireland, ACCA or CPA Ireland), a solicitor supervised by the Law Society of Ireland, a PSRA-licensed estate agent and a TCSP supervised by the AMLCU all face the same onboarding question: which register holds this client's beneficial-ownership information?

Register one: the RBO for companies

The RBO is the register most firms know, and it carries the most concrete obligations for designated persons. Since April 2021, before entering a new business relationship with a company or industrial and provident society, your firm must obtain an extract of the client's beneficial-ownership information from the RBO.

Two things about RBO access trip firms up.

First, access is tiered following the Court of Justice of the EU's ruling on public access. Competent authorities get full Tier 1 access; designated persons get restricted Tier 2 access. Your firm registers for designated-person access using the BEN3A1 form, and each extract carries a small per-search fee of a few euro.

Second, there is no public API. Obtaining an extract is a manual process, so your procedures need to say who pulls it, where it is stored, and how it is linked to the client file — a supervisor reviewing your CDD will expect to see the extract itself, not a note saying someone looked.

The duty most firms miss: discrepancy reporting

Obtaining the extract is only half the RBO obligation. Under Regulation 20(3)(b) of SI 110/2019, if your firm finds a discrepancy between what the register says and the beneficial-ownership information you establish through your own due diligence, you must report that discrepancy to the Registrar.

In practice this means your onboarding workflow needs a comparison step, not just a filing step:

1. Obtain the RBO extract before the business relationship begins.
2. Identify the beneficial owners yourself through your normal CDD — ownership documents, structure charts, declarations.
3. Compare the two.
4. Record the outcome: either they match, or they do not and you have notified the Registrar.

A file that contains an extract but no recorded comparison does not evidence the discrepancy duty. If your current process is "download the PDF and save it to the folder", it is doing step 1 of 4.

Register two: CRBOT for trusts

Trusts do not appear on the RBO. Their beneficial-ownership information sits on CRBOT, the Central Register of Beneficial Ownership of Trusts, maintained by the Revenue Commissioners.

This matters more often than firms expect. Trusts turn up routinely in ordinary work: a family trust holding a property being sold through an estate agent, a trust as shareholder in a company an accountant is onboarding, trust structures in probate and conveyancing files, and — for TCSPs — trust administration as the core service itself. Whenever the client, or an entity in the client's ownership chain, is a trust, CRBOT is the relevant register, and your procedures should say so explicitly rather than defaulting to the RBO.

Register three: the Central Bank register

The third register, maintained by the Central Bank of Ireland, covers certain financial vehicles: ICAVs, unit trusts and credit unions. Most small practices meet these entities less often, but if your firm acts for fund vehicles or a credit union, this is where their beneficial-ownership information lives — not the RBO. A one-line entry in your CDD procedure ("ICAVs, unit trusts and credit unions: consult the Central Bank register") prevents a team member searching the wrong register and concluding, wrongly, that no filing exists.

What the EU package changes

Three developments are worth building into your planning now.

A harmonised 25% threshold. The AMLR sets an EU-wide definition of beneficial owner at 25% or more ownership interest, direct or indirect. The Commission may later lower the threshold — to 15% or lower — for high-risk sectors by delegated act, following a review due by 2029. Your ownership-analysis procedures should treat the threshold as a configurable number, not a hard-coded one.

Registers connected EU-wide. AMLD6 provides for interconnection of member states' beneficial-ownership registers through the BORIS system, and gives registrars new verification powers. Register data becomes easier to cross-check, and discrepancies easier for authorities to spot. These AMLD6 provisions are staggered ahead of the main package — register access from 10 July 2025, core register articles and technical standards from 10 July 2026 — so this is happening now, not in 2027.

The rulebook switches on 10 July 2027. From that date the AMLR — directly applicable, no Irish transposition needed — governs your beneficial-ownership obligations as an "obliged entity" (the AMLR's term for what Irish law calls a designated person). Policies that cite only the CJA 2010 framework will be out of date on day one.

What to do now

• Map your client base against the three registers: companies and industrial and provident societies (RBO), trusts (CRBOT), ICAVs, unit trusts and credit unions (Central Bank register).
• Check your firm has live designated-person access to the RBO (BEN3A1) and that more than one person knows the login and process.
• Add an explicit comparison-and-record step to onboarding so the discrepancy duty under Regulation 20(3)(b) of SI 110/2019 is evidenced on every corporate file.
• Update procedures to name all three registers, with a one-line routing rule for which entity type goes where.
• Write the 25% beneficial-ownership threshold into your templates as a parameter, noting the possible future reduction to 15% for high-risk sectors.
• Diary a beneficial-ownership procedure review ahead of 10 July 2027, when the AMLR becomes the applicable rulebook.

How CompliDesk helps

CompliDesk Ireland builds the RBO workflow into onboarding: it prompts for the extract before a new business relationship, stores it on the client file, and records the comparison and discrepancy decision so the evidence is there when your supervisor asks. See how the wider rulebook is changing in the AMLR explainer.