RBO extracts step by step: BEN3A1 access, fees, and what to do about discrepancies

If your firm takes on companies as clients, checking the Register of Beneficial Ownership (RBO) is not optional. Since April 2021, designated persons in Ireland have been required to obtain an RBO extract before entering a new business relationship with a relevant entity — and to report discrepancies between what the register says and what your own checks find. Yet in many small practices this step still happens inconsistently, late, or not at all.

That gap matters more now than it ever has. From 10 July 2027, Regulation (EU) 2024/1624 (AMLR) becomes the directly applicable AML rulebook for Irish firms, and it puts harmonised beneficial-ownership obligations at the centre of customer due diligence. A tidy, repeatable RBO routine is one of the easiest things to fix before then. Here is how the process actually works, step by step.

First, make sure you are looking at the right register

Ireland has three beneficial-ownership registers, and asking the wrong one is a common mistake:

• The RBO (rbo.gov.ie) covers companies and industrial and provident societies. This is the register most firms deal with day to day.
• CRBOT, operated through Revenue, covers trusts.
• The Central Bank of Ireland register covers ICAVs, unit trusts and credit unions.

This guide covers the RBO. If your client is a trust or a fund vehicle, the same underlying duty applies, but you will be dealing with Revenue or the Central Bank instead.

Step 1: register for designated-person access using form BEN3A1

Following the Court of Justice of the EU's ruling on public access to beneficial-ownership registers, RBO access is tiered rather than open to everyone:

• Tier 1 — competent authorities, with full access.
• Tier 2 — designated persons, with restricted access sufficient to carry out customer due diligence.

Your firm falls into Tier 2. To get access, you register with the RBO using form BEN3A1, confirming your status as a designated person under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. Do this once, up front. If several people in your firm handle onboarding, decide who holds the access and how requests are routed to them.

One practical point worth knowing before anyone asks: there is no public API for the RBO. Extracts are obtained through the portal, one entity at a time. Any process you build has to be a human workflow with good record-keeping, not an automated data feed.

Step 2: obtain the extract before the relationship starts, and budget the fee

The obligation is to obtain the extract before entering the new business relationship — not during the first month, and not when the file is being tidied for review. The extract is meant to inform your due diligence, not decorate it afterwards.

Each extract carries a modest per-document fee, in the region of a few euro (roughly €2.50 per extract at the time of writing — check the current fee on rbo.gov.ie). For most firms the cost is trivial; the discipline is what matters. Save the extract itself to the client file with a date. An extract you cannot produce later is, for evidential purposes, an extract you never obtained.

Step 3: compare the extract against what the client told you

The extract is not the end of your beneficial-ownership work — it is one input. You should already have asked the client who their beneficial owners are as part of customer due diligence. Under the AMLR, the harmonised EU-wide test is a 25% or more ownership interest, direct or indirect (the European Commission may later lower this to as little as 15% for high-risk sectors by delegated act, following a review due by 2029).

Now compare the two sources:

A hypothetical example: your onboarding questionnaire and the company's own structure chart show two directors each holding 50% of a client company, but the RBO extract lists only one of them. That mismatch is exactly what the discrepancy regime exists to catch, and it needs a documented response — not a shrug.

Step 4: deal with discrepancies properly

Where the register does not match what your checks establish, designated persons must report the discrepancy — the duty sits in Regulation 20(3)(b) of SI 110/2019. In practice your file should show four things:

1. What the extract said, and what your own information said.
2. The follow-up you did — usually going back to the client for an explanation or supporting documents.
3. Your decision: genuine discrepancy, or a resolved misunderstanding (for example, a recent change the company had filed but you were reading an older extract against).
4. If it was a genuine discrepancy, the notification you made to the Registrar, with the date.

Resist the temptation to quietly accept the client's verbal explanation and file nothing. The comparison, the reasoning and the outcome should all be written down, whichever way the decision goes.

What changes under the AMLR and AMLD6

Two things are worth flagging for the run-up to 10 July 2027. First, the AMLR harmonises the beneficial-ownership rules themselves EU-wide, so your definition of who counts as a beneficial owner will come from Regulation (EU) 2024/1624 rather than a purely national reading. Second, Directive (EU) 2024/1640 (AMLD6) connects national registers across the EU via BORIS and gives registrars new verification powers — meaning register data should improve over time, and discrepancy reports will feed a system with more teeth. Neither change removes your duty to check and compare; both raise the standard your file will be judged against. Remember, too, that the AMLR requires records to be retained for five years and then deleted, so your stored extracts need a retention discipline as well as a filing one.

What to do now

• Register for RBO designated-person access via form BEN3A1 if you have not already, and record who in the firm holds it.
• Write a one-page procedure: extract before onboarding, save with a date, compare against CDD, document the outcome.
• Add the comparison step to your onboarding checklist so it cannot be skipped.
• Spot-check five recent corporate client files: is there a dated extract and a recorded comparison in each?
• Confirm which register applies to each entity type you serve — RBO, CRBOT or the Central Bank register.
• Diarise a refresh of your beneficial-ownership procedures against the AMLR text before 10 July 2027.

How CompliDesk helps

CompliDesk Ireland is building a guided RBO workflow for exactly this routine: a before-onboarding prompt, extract storage, a structured comparison record, and a logged discrepancy decision — all AMLR-ready from day one. See how the wider rulebook is changing in our AMLR explainer.