Getting designated-person access to the RBO: the BEN3A1 form, step by step

Before your firm takes on a new corporate client, Irish law expects you to check the Register of Beneficial Ownership (RBO) — and to say something if the register does not match what you find. To do either, you first need designated-person access. Here is how it works.

Why does your firm need RBO access?

Since April 2021, designated persons must obtain an RBO extract before entering a new business relationship with a company or industrial and provident society. The extract is not a substitute for your own beneficial-ownership checks — it is a cross-check. You compare what the register says against what the client has told you, and under Regulation 20(3)(b) of SI 110/2019 you must report discrepancies between the two to the Registrar.

Without access, your firm cannot perform either half of that duty. Applying for access is therefore one of the standard onboarding steps for any new Irish designated person, alongside goAML and ROS registration — see our supervisor onboarding checklist.

What is Tier 2 access?

Following the Court of Justice of the EU’s ruling on public access to beneficial-ownership registers, RBO access is restricted to two tiers. Tier 1 gives competent authorities — supervisors, law enforcement and similar bodies — full access. Tier 2 gives designated persons restricted access: enough to obtain the extract you need for customer due diligence, but not the open public search that existed before. The BEN3A1 form is how a firm establishes its entitlement to Tier 2. There is no public API — extracts are requested through the RBO’s own process, which is why this works best as a documented workflow inside your onboarding procedure.

How do you apply with the BEN3A1 form?

The outline below covers the general shape of the application. The RBO sets the exact form contents and submission route, so follow the current instructions on rbo.gov.ie when you apply.

1. 1

   Get the BEN3A1 form from rbo.gov.ie

   The BEN3A1 is the application form for designated-person access to the RBO. Download the current version and its instructions from rbo.gov.ie — the form and procedure are set by the Registrar, and rbo.gov.ie is the authoritative source for both.

2. 2

   Complete the firm and designated-person details

   The form identifies your firm, its designated-person status and the basis on which you are entitled to restricted access. Complete it accurately and consistently with your other regulatory records.

3. 3

   Submit the application as the RBO directs

   Follow the submission instructions published with the form. Keep a copy of the completed application and the date you sent it in your compliance file.

4. 4

   Wait for confirmation of Tier 2 access

   The RBO reviews the application before granting access. Once confirmed, record who in the firm holds the access and how requests for extracts are made and logged.

5. 5

   Request extracts as part of onboarding — €2.50 each

   With access in place, obtain an extract before entering each new business relationship. Each extract costs a flat €2.50. Store the extract on the client file alongside the beneficial-ownership information the client gave you.

What is the discrepancy-reporting duty?

For every new business relationship, compare the RBO extract against the beneficial-ownership information the client provided. If the two do not match — a missing owner, a different percentage, an out-of-date entry — Regulation 20(3)(b) of SI 110/2019 requires you to report the discrepancy to the Registrar. Record the comparison and the decision either way: an extract on file with no note of what you concluded is weak evidence at inspection. If you do report, keep the notification and any follow-up on the client file.

What about trusts and other entities?

The RBO covers companies and industrial and provident societies. Ireland has two further beneficial-ownership registers: CRBOT, the trusts register operated through Revenue, and the Central Bank of Ireland’s register for ICAVs, certain unit trusts and credit unions. If your client base includes trusts or fund vehicles, your onboarding procedure needs to route the check to the right register.

What changes under the AMLR?

From 10 July 2027, Regulation (EU) 2024/1624 harmonises the beneficial-owner definition EU-wide at 25% or more ownership interest, direct or indirect. Following a review due by 2029, the Commission may set a lower threshold for certain high-risk sectors by delegated act — 15% or lower. In parallel, Directive (EU) 2024/1640 connects national registers across the EU via BORIS and gives registrars new verification powers. The practical duty for your firm — check the register, keep the evidence, report discrepancies — carries across, so a clean RBO workflow now is work you keep.