Home Is Where the Redaction Is: Directors’ Addresses and the CRO’s Proposed Privacy Reforms

Consultation on Proposed Changes to the Companies Act

The Department of Enterprise, Trade and Employment (“DETE”) is considering amendments to the Companies Act 2014 (the “Companies Act”) following its 2025 public consultation, which proposed replacing the public disclosure of directors’ and secretaries’ residential addresses on the CRO with a designated “contact address”. These proposals are a welcome approach and aim to address concerns of personal privacy and personal data for directors and secretaries in Irish companies.

In response to the consultation, the Company Law Review Group (the “CLRG”) published a report in September 2025 reviewing the current position on disclosure requirements for directors and secretaries having regard to company transparency requirements and GDPR.

The consultation closed on 19 December 2025 and any changes would be expected to take effect from 2026, subject to the legislative process and commencement.

The Current Position

Under section 149 of the Companies Act, companies must keep a register of directors and secretaries that includes each officer’s usual residential address. This information is then filed with the Companies Registration Office (the “CRO”) and made available for public inspection.

However, an exemption may be available where an officer can show that publication of their residential address poses a real risk to their personal safety or security (or such other conditions as may apply). This is provided for under the Companies Act 2014 (Section 150) (No. 2) Regulations 2015, S.I. No. 543/2015 (the “2015 Regulations”). In such a case, a Form TR1 request can be submitted to the Registrar of Companies, and the application process involves confirmation from An Garda Síochána (the Irish police) that disclosure would pose a risk. This exemption is, however, limited in scope.

Proposed Amendments to the Companies Act 2014

The proposed amendments are as follows:

• Directors and secretaries of companies will have the option of providing a “contact address” which can be made public instead of their residential address.
• This contact address may be the company’s registered office or any other as prescribed by the Minister for Enterprise, Tourism and Employment, provided it is in the State and suitable for serving documents on the officer.
• This “contact address” will be the only address made public on the CRO Register and the company’s Register of Directors and Secretaries.
• The company and the CRO would still hold the officer’s residential address, but this will be disclosable only to prescribed persons, such as law enforcement officials, or on foot of a court order.
• It is intended to repeal the 2015 Regulations. Consequently, a relevant officer previously granted an exemption under the 2015 Regulations may continue to use the alternate address as the “contact address” but will be required to provide “a usual residential address”.
• The amendments would have no retrospective effect. Residential addresses disclosed in prior CRO filings would continue to be accessible on those historic records.

The proposed changes aim to improve personal safety and reduce the risk of harassment or misuse of personal data. The intention is also to bring the Irish approach more in line with systems used in other common law jurisdictions.

The CLRG comments that these changes can support transparency while still enabling relevant officers to be identified. The CLRG also notes that Ireland may draw on approaches used in other jurisdictions (including the UK) to balance individuals’ privacy with continued access to essential information for specified organisations and officials.

Key Considerations for Directors Going Forward

• The proposed changes are not intended to apply retrospectively, so residential addresses disclosed in historic CRO filings would remain accessible on those records.
• Directors and secretaries should consider whether any additional personal security or privacy steps are needed, given continued visibility of historic filings.
• Review your company’s prior CRO filings and confirm what address is currently displayed for each relevant officer.
• Once enacted, the legislation would introduce a new compliance approach, so companies and officers should plan early rather than wait for commencement.
• Companies should anticipate additional internal record-keeping so that the usual residential address is retained securely while only the contact address is used for public-facing purposes.
• In practice, companies may need to operate two address records for each relevant officer:
• • a public record showing the contact address (for CRO and register inspection purposes), and
  • a restricted record retaining the usual residential address, available only to prescribed persons or on foot of a court order.

What Directors and Companies Should Do Now

• Audit historic CRO filings for current and former directors/secretaries to understand what residential address information is already in the public record.
• Decide what contact address will be used going forward (e.g., registered office) and ensure it is suitable for service of documents.
• Update internal processes so the usual residential address is captured, stored securely, and disclosed only where legally permitted.
• Monitor the legislation’s progress and commencement arrangements so any filings can be aligned promptly once the new regime is in force.

How We Can Help

If you have any queries or concerns, or would like to discuss the above in further detail, please feel free to contact Susan Noone or Theriz Von Mag-aso in our Corporate Department on snoone@bhsm.ie / tmagaso@bhsm.ie.

We can assist you in taking your next steps if the above affects you as a director or another director or directors in your company. This may include changing your current registered address or notifying a director to make such a change.

This article is for general information purposes. Legal advice must be obtained for individual circumstances.  Whilst every effort has been made to ensure the accuracy of this article, no liability is accepted by the author for any inaccuracies.