# Verification record — `ie/cro/company-incorporation` v1.0.0 This file is the **source-review record** for this document version, per the [`manual-source-review-v1`](../../../../practices/manual-source-review-v1.md) practice. It documents the provenance of the published fields and flow and states the current verification claim honestly. ## Current claim - **`status`:** `draft` - **`verification.method`:** `manual-source-review-v1` - **`verification.lastVerifiedAt`:** `2026-07-01` The document was **derived from and cross-checked against** the official sources below, but the full field-by-field comparison the practice requires (`manual-source-review-v1` → Procedure step 2) has **not** yet been completed and recorded against the live CORE (Companies Registration Online Environment) filing screens. It therefore remains `draft`, not `verified`. ## Why this schema and why now (GOV-409) GOV-409 is a recurring "GovSchema Standard Research" brief scoped to five verticals: DMV, Business Formation, Visa, Passport, Taxes. A catalog audit (discovery/catalog.json: 82 candidates, 41 published across 8 jurisdictions before this cycle) found Business Formation only published for GB (`gb/companies-house/company-incorporation-in01`) and US-CA (`us/ca/sos/business-entity-llc-formation`, plus the EIN identifier), leaving two logged tier-2 candidates unauthored: `ie/cro/company-incorporation` and `ca/on/registration/business-incorporation`. This continues the prior GOV-381 research cycle's own "Next" note, which flagged both as good targets. Ireland was chosen over Ontario because CRO is a single national authority (like GB, unlike the US or Canada's provincial/federal split noted in `discovery/README.md`), it already has three published IE schemas to build authority-coverage alongside (`ie/dfa/*` passports, `ie/dsp/pps-number-application`, `ie/dttas/driving-licence-renewal`), and its Form A1 requirements are well-documented across multiple independent public pages. ## Sources examined - **Document `(id, version)`:** `ie/cro/company-incorporation` / `1.0.0` - **Spec version:** GovSchema `0.2.0` - **Authority:** Companies Registration Office (CRO), Ireland. - **Primary source URLs** (all under `cro.ie`): - `/registration/company/required-steps/` — Form A1 and constitution overview, the Fé Phráinn vs. Ordinary Online A1 distinction (partially; full detail from `/registration/company/registration-methods/`), NACE code requirement. - `/information-leaflets/company-incorporation-leaflet-1/` — company types, the LTD-specific rules (one document constitution, no memorandum, one director allowed with a separate secretary), the full Checklist for Constitution (subscriber signature/witnessing, share statement rules, prohibited objects). - `/registration/company/incidental-obligations/company-officers/` — director/ secretary minimums by company type, age (18+) and undischarged-bankrupt restrictions (Companies Act 2014 ss.131-132), the EEA-resident-director requirement and Section 137 bond, the secretary rules (may be a body corporate, must be separate from a sole director), the "note on completing Form A1" for other-directorships disclosure and its exceptions, and the 25-company directorship cap (s.142). - `/registration/company/incidental-obligations/registered-office/` — registered-office physical-location and An-Post-deliverability rules. - `/registration/company/incidental-obligations/company-name/` — name objection/similarity rules (Companies Act 2014 s.30), reservation mechanics (out of scope of this document, noted for completeness), and the reserved suffix words requiring third-party permission (out of scope: none of this document's fields model those restricted words). - `/registration/company/registration-methods/` — Ordinary Online A1 (10 working days) vs. Fé Phráinn A1 (5 working days, requires a separate CRO-preapproved promoter constitution template) schemes, and the company name reservation fee/mechanics. - **Secondary source (corroboration):** cpdstore.ie, "What is Required to be Filed to Incorporate a Company?" (Lauren Doyle, CPD Store, published 2023-04-28) — a practitioner CPD explainer that lists the Form A1 field set end-to-end (company name, type, director/secretary/subscriber particulars, registered office, NACE code, share capital fields, constitution requirements) and the online filing fee (€50) and file-upload/signature mechanics (PDF upload, 8 MB cap, wet-signature requirement, witness restriction). Used because cro.ie's own pages, while authoritative on rules, do not present the Form A1 field list as a single consolidated table; this secondary source was used to cross-check field completeness, not as the primary source for any legal rule. - **Retrieval method:** `cro.ie` returns HTTP 403 to direct automated fetch from this environment (same class of block noted on other jurisdictions' sites in prior authoring passes, e.g. `passports.gov.au`). Every `cro.ie` page above was instead retrieved via `web.archive.org` Wayback Machine snapshots dated between 2025-12-10 and 2026-03-09, decompressed to plain text, and read in full (not summarized by a third-party tool). - **Official form id:** Form A1 ("Form of incorporation of a new company"). - **Retrieved / reviewed:** 2026-07-01. - **Reviewer:** GovSchema Engineering (initial authoring source-review). ## What was confirmed against the source | Source section | Field(s) | |---|---| | Company Name — naming rules | `companyName` | | Company Incorporation (Leaflet 1) — NACE code | `natureOfBusinessDescription`, `naceCode` | | Registered Office — physical location | `registeredOfficeAddressLine1/2`, `registeredOfficeEircode` | | Form A1 required particulars (company email) | `companyEmailAddress` | | Company Officers — Directors and Secretaries | `directorFullName`, `directorDateOfBirth`, `directorNationality`, `directorOccupation`, `directorResidentialAddressLine1/2`, `directorResidentialAddressCountry` | | Company Officers — note on completing Form A1 | `directorOtherDirectorships` | | Company Officers — EEA residency / Section 137 | `directorIsEeaResident`, `section137BondArranged` | | Company Officers — the Secretary | `secretaryIsBodyCorporate`, `secretaryFullName`, `secretaryDateOfBirth`, `secretaryNationality`, `secretaryResidentialAddressLine1/2`, `secretaryResidentialAddressCountry`, `secretaryCorporateName`, `secretaryCorporateRegistrationNumber` | | Checklist for Constitution — subscriber requirements | `subscriberName`, `subscriberAddressLine1/2`, `subscriberAddressCountry`, `numberOfSharesSubscribed` | | Checklist for Constitution — LTD nominal-capital allowance | `nominalValuePerShare` | | Forming a company — constitution requirements | `constitutionType` | | Checklist for Constitution — signature/witnessing | `constitutionDocument`, `subscriberSignatureWitnessName` | | Forming a company — Form A1 declaration | `lawfulActivityDeclarationConfirmed` | | cpdstore.ie — Form A1 submission requirements | `formA1WetSignatureConfirmed`, `directorPpsn` (flagged, see below) | ## Scope narrowing and why GovSchema v0.2 fields are flat (SPEC.md §6.1): there is no array or repeating-group construct ([GSP-0009](../../../../spec/proposals/0009-composite-repeating-values.md) tracks a future addition). Form A1 supports an arbitrary number of directors, subscribers, and share classes, so — following the same precedent as `gb/companies-house/company-incorporation-in01` and `us/ca/sos/business-entity-llc-formation` — this document is scoped to the **single-director, single-secretary, single-subscriber, single-share-class Private Company Limited by Shares (LTD)** case: the common individual-founder scenario, and the only Irish company type that may have just one director. Concretely, **out of scope** for v1.0.0: - Designated Activity Companies (DAC), public companies (PLC/PUC/PULC), Companies Limited by Guarantee (CLG/DAC-by-guarantee), unlimited companies, Societas Europaea, and UCITS — all require a minimum of two directors and/or a two-document (memorandum + articles) constitution with stated objects, unlike the LTD's one-document, no-objects constitution this document models. - More than one director, secretary, subscriber, or share class — the source form's repeatable blocks for each are not modelled. - The **Fé Phráinn A1** fast-track scheme — it requires a promoter to have a draft constitution pre-approved by the CRO as a standing template before any individual incorporation, a separate multi-step relationship out of scope of a single incorporation's data model. `constitutionType` therefore only distinguishes the CRO's standard downloadable LTD constitution from a bespoke one, both filed under the Ordinary Online A1 scheme. - **Company name reservation** — an optional, separate pre-step (RCN application, €25, 28-day hold) that produces a certificate presentable alongside a later Form A1 for a fee offset. Not part of Form A1 itself. - The **Register of Beneficial Ownership (RBO)** filing — a distinct post-incorporation statutory filing (separate from Form A1) with its own PPSN-verification regime; out of scope of this document entirely. - **Fees** (name reservation €25, incorporation €50 per the secondary source) — payment metadata, not applicant-collected data, consistent with how other schemas in this registry (e.g. `au/apo/passport-application-first-adult`) treat fees. ## What is NOT yet independently verified - **`directorPpsn`/PPSN mandatoriness on Form A1 itself.** The secondary source (cpdstore.ie, dated April 2023) lists PPSN as "soon to be required" for directors on Form A1. The CRO's own current (2026) "Company Officers" page, read in full for this review, does not restate a PPSN requirement for Form A1 in its body text — it only references PPSN in navigation links pointing to the separate Register of Beneficial Ownership ("Beneficial Owners with no PPSN"). It is plausible the phased-in requirement mentioned in 2023 has since taken effect for Form A1 itself (Ireland's Companies (Corporate Enforcement Authority) Act 2021 introduced PPSN disclosure duties for company officers more broadly), but this review could not confirm that directly against a live CORE Form A1 field list. `directorPpsn` is therefore modelled as `required: false` (optional) rather than mandatory, and this is the single most important open item for the next reviewer to resolve — ideally by inspecting the live CORE filing screens directly, which this review's Wayback-only retrieval method could not do. - **`registeredOfficeEircode` mandatoriness** — the Registered Office source page describes the address requirement in full but does not explicitly list Eircode as a separate mandatory Form A1 field (as distinct from being part of a complete Irish postal address); modelled as optional. - **`naceCode` pattern** — inferred from example NACE codes in general use (e.g. `62.02`, `10.83`) as the EU NACE Rev. 2 two-digit-division / optional-two-digit-subclass structure; the CRO's own NACE code PDF (referenced but not linked with a stable URL on the Leaflet 1 page) was not independently retrieved to confirm the exact permitted string format CRO's CORE system expects (e.g. whether the separator dot is required, optional, or omitted entirely in the online form field). - **Online CORE screen order and wording** were not captured screen-by-screen; `sourceRef` annotations cite the named cro.ie guidance pages' own section headings, which are believed to mirror the CORE filing flow's field groupings but this was not independently confirmed field-by-field against the live online service (the same caveat `gb/companies-house/company-incorporation-in01` records for `register-a-company-online`). - **Section 137 bond mechanics** — confirmed as a real substitute for the EEA-resident-director requirement from the Company Officers page, but the bond's own application process, cost, and required particulars are a separate undertaking not modelled here (`section137BondArranged` records only the declaration that one is in place). ## Mock test run (phase 4) Two realistic payloads and one deliberately invalid payload were checked field-by-field against every field's `type`/`required`/`validation` rule, the conditional-requiredness relationships described in field text (`directorIsEeaResident` → `section137BondArranged`; `secretaryIsBodyCorporate` → the individual vs. corporate secretary field groups), and `steps[].fields` referential completeness (every field appears in exactly one step; no step references an undeclared field). 1. **Single-director, EEA-resident, standard constitution** — an Irish director/subscriber (same natural person) forming a small LTD trading business, EEA-resident (so no Section 137 bond needed), a separate individual Irish secretary, 100 shares at €1 nominal value, the CRO's standard LTD constitution. **Result: valid**, all fields pass. 2. **Non-EEA-resident director with a Section 137 bond, body-corporate secretary, bespoke constitution** — a UK-resident (non-EEA since 2021) director/subscriber with a bond in place, a corporate-secretary provider (common in practice, e.g. a formation-agent-supplied secretarial company), a single share, and a bespoke (non-standard) constitution. **Result: valid**, all fields pass, exercising the `secretaryIsBodyCorporate: true` branch and the Section 137 conditional path together in one payload. 3. **Deliberately invalid payload** — a 2-character company name (fails `minLength: 3`), a malformed NACE code `"ABCDE"` (fails the numeric pattern), a PPSN without its required letter suffix (fails pattern), zero subscribed shares (fails `minimum: 1`), an unrecognized `constitutionType` value (fails enum), `directorIsEeaResident: false` with no `section137BondArranged` declaration, and `secretaryIsBodyCorporate: true` with neither corporate-secretary field given. **Result: correctly rejected** — all 8 induced errors were caught (5 field-level validation failures, 3 conditional-requiredness failures), confirming the schema detects each class of error independently. All three payloads were also checked against `schema.json`'s `steps` array: every field is reachable from `steps[0]` through `next` chaining, and no field is orphaned from a step. ## Path to a `verified` claim (next step) To advance to `status: verified`, a reviewer applies `manual-source-review-v1` (Procedure step 2) field-by-field against the live CORE Form A1 filing screens specifically (not just the cro.ie guidance pages), resolves the `directorPpsn` mandatoriness question above as the top priority, confirms the NACE code pattern against CRO's own NACE code list PDF, resolves any discrepancy by shipping a **new schema version** (immutability — VERSIONING §3, practice Procedure step 5), and records the outcome here plus sets `status: verified` with a current `verification.lastVerifiedAt`/`nextReviewBy`. ## Re-verification Per the practice's **Cadence**, `nextReviewBy` is set to **2027-01-01** (6 months). Re-check the source on or before that date and on any `source.url` change, and specifically re-check whether PPSN has become a confirmed mandatory Form A1 field by then.