Irish Company Law: Three New Strike-Off Grounds Now Active; Enhanced Enforcement Powers for CRO
Companies Act 2024 (effective 3 December 2024) introduces three new strike-off grounds: unnotified office change, missing company secretary, RBO non-compliance. Material expansion of CRO enforcement powers.
The Companies Act 2024 has materially expanded strike-off grounds. In addition to annual return failure, the CRO Registrar may now strike off for: (1) failure to notify CRO of registered office change; (2) failure to record a current company secretary; (3) RBO non-compliance notified to the CRO.
Unlike traditional annual return failures (which escalate with warnings), these new grounds may be triggered without prior notice. Company housekeeping is now a legal compliance requirement with direct consequences for registration status.
What You Need to Do
Audit all Irish companies in your portfolio: (1) registered office - confirm CRO record matches actual location and changes notified; (2) company secretary - confirm current secretary recorded; (3) beneficial ownership - verify RBO filing current. Establish processes to flag changes with mandatory notification. For gaps, initiate compliance immediately or consider voluntary strike-off if company is unused.