The original registration process was unfit for UK Trustees, as it assumed they would access the CRBOT through the Revenue’s Online Service (ROS). This proved cumbersome, leading to the suspension of the registration process for UK Trustees while an alternative solution was sought. However, this suspension did not remove the requirement for Irish life companies to check for discrepancies between the information provided by Trustees and the register.
Several members of the Utmost Technical Services team, as active participants in insurance industry bodies, have been directly involved in discussions with the Irish Revenue and the CRBOT to resolve the registration issues for both UK Trustees and life companies.
It is anticipated that by the end of this year, UK and other non-EU trustees with Irish policies will be able to register on the CRBOT by completing a downloadable spreadsheet from the CRBOT website. Comprehensive guidance on how to register will also be provided. Once submitted, UK Trustees will receive a reference number in a letter, instructing them to contact their life policy provider for discrepancy checks against the register.
While the availability of the registration process is welcomed, several issues remain:
- A large number of UK trustees need to register, potentially leading to a surge in registrations. Life companies will receive an access code (via the trustee) but currently have only a small window in which to check for discrepancies.
- If the registration requirement is not effectively communicated to UK Trustees (many of whom are lay trustees), it may be ignored, resulting in potential financial penalties.
Utmost Technical Services team will continue to collaborate with the industry and the Irish Revenue to address these issues.