Ireland proposes residential address opt-out for company officers

Neil Keenan of Pinsent Masons was commenting following a recent consultation by Ireland’s Department of Enterprise, Tourism and Employment (DETE) on amendments to the Companies Act 2014 to remove the current requirement for company directors and individual company secretaries to include their residential addresses on publicly available company filings.

The consultation followed a report published in September 2025 by Ireland’s Company Law Review Group (CLRG) which said that the requirement raised security concerns for company officers of companies registered in Ireland.

The CLRG, a statutory expert advisory body tasked with advising the department on company law reform, recommended that the law should be changed to preclude the default requirement for directors’ and secretaries’ “usual residential address” to be publicly displayed and accessible on Ireland’s Companies Registration Office (CRO).

The Companies Act 2014 permits individuals to apply for an exemption to withhold their residential address for safety or security reasons, but this is still subject to approval from Ireland’s national police force, the Gardaí. In practice, the exemption also provides individuals with limited protection as any address details already published on the register remain available.

In its report (43 pages, 2.2MB), the CLRG said it had become clear that this requirement posed "safety and security" risks to both relevant officers and other "unconnected" individuals that may reside at the same residential address, including partners, elderly persons, vulnerable persons and children.

The law in its current form also raises potential data protection issues under the EU’s General Data Protection Regulation, which has been implemented in Ireland primarily through the Data Protection Act 2018.  

DETE sets out a number of proposed amendments in the consultation paper to balance these risks. These include making the residential addresses of all company directors and individual company secretaries non-public. Instead, these addresses would be retained internally and held confidentially by the company and the CRO.

Under the proposals, a new “contact address” would be introduced whereby officers would instead be required to provide a contact address that would appear publicly. This could be their usual residential address, the company’s registered office, or another Irish-based address.

Access to residential addresses would be solely restricted to specified entities such as the Revenue Commissioners, the Central Bank, the courts and the Gardaí. Court-ordered disclosure will remain possible, allowing courts to compel a company or the CRO to release a company officer’s usual residential address if necessary for serving legal proceedings or in the pursuit of justice.

DETE also proposes to repeal the current exemption route and that all protections for residential addresses would be embedded in primary legislation. As recommended by the CLRG, any legislative change would not have retrospective effect, meaning that past filings that include residential addresses would remain publicly available, but all future filings would follow the new approach and apply from when legislative changes come into effect.

Neil Keenan, who is a Dublin-based corporate governance expert and also a member of the CLRG and Business Law Committee of the Law Society of Ireland, said the proposed changes aimed to strike a balance between transparency and the privacy and security of individual company officers, and would bring Ireland in line with other jurisdictions. “It cannot be the price of being a company officer that your privacy and security along with those of others who happen to live at the same address is compromised,” he said.

“The CLRG, as outlined in its report, did receive presentations from Transparency Ireland and the Data Protection Commission along with a review of the position in other common law and EU jurisdictions. Ireland is clearly an outlier in having residential addresses freely available online to the public which is a real concern when we are competing with other jurisdictions for inward investment.”

There has also been some adverse commentary about this change in Irish media with one media outlet going so far as to suggest the change will “undermine democracy”. Journalists have also expressed concerns that the changes will impede investigative journalism in areas such as corporate fraud.

However, Keenan made the point that, in a world of increased risks of identity fraud and increasing online and physical harassment of individuals, the public availability to anyone of the residential addresses of directors has created unacceptable personal risks to them. Keenan also noted that the residential addresses will still be available to the relevant authorities and to facilitate the service of legal proceedings.

He also said that in other common law jurisdictions, such as the UK, Singapore and New Zealand, there is no equivalent requirement for company officers to display their usual residential address and those jurisdictions have implemented similar changes to those which are currently being considered by Ireland. Amid rising concerns over security and privacy for individuals, Keenan added that the current requirement could put Ireland at a serious disadvantage when competing for inward investment.

In its submission to the consultation, the Law Society of Ireland said the country’s residential address requirement was “out of step with best practice in other jurisdictions” and it welcomed a change in legislation. However, it said that the CRO’s cost justification for the change not applying retrospectively did “not stand up to scrutiny”. While it recognised that “a wholesale review and redaction of historic filings would require significant resources”, it reasoned that “a targeted, application-based mechanism would strike a proportionate balance between transparency and personal security.”

Keenan said the proposed change without retrospective effect would be of limited benefit to individuals who are already or were formerly company directors, unless they happen to move from the residential address recorded at the CRO. He urged the necessary resources be made available to the CRO to redact a residential address if requested by a company director.

The consultation closed on 19 December. It is expected that the government will publish its response and any plans for legislative reform later in 2026