Registering Charges Over Company Assets in Ireland: CRO Filing Explained

If a company gives a lender security over its assets, the lender will usually want that security registered at the Companies Registration Office (CRO). Under the Companies Act 2014, failing to register in time can leave the charge void against the company's liquidator and creditors. This guide sets out what the CRO and the Irish Statute Book say about registering charges, the 21-day period, the forms used and the consequences of getting it wrong. Rules and fees change, so check the current figures on the official pages and take advice for your own situation.

What a registered charge is for

Section 414 of the Companies Act 2014, "Register of charges", requires the Registrar to keep a register of charges that must be registered under the relevant Part. For each charge it records the creation date, the date and time the Registrar received the required particulars or notices, a short description of the charged property and the persons entitled to the charge. The Irish Statute Book text says the register is open to anyone to inspect, for a prescribed fee if one applies.

Charges often arise when a company borrows or is first set up with finance. If you are working on a new company, see our guide to incorporating a private company limited by shares for the wider CRO process.

The core rule: 21 days

Section 409 of the Companies Act 2014, headed "Registration of charges created by companies", covers charges a company creates after the section comes into force. It provides two procedures:

• One-stage: the Registrar must receive the prescribed particulars within 21 days of the charge's creation.
• Two-stage: the Registrar first receives a notice of intention, and within 21 days of receiving that notice a second notice confirming the charge has been created must follow. If the confirmation is not filed in time, the Registrar removes the advance notice from the register.

The CRO page on mortgages and charges (last modified 24 March 2026) gives the same 21-day periods and says the forms are C1 for the one-stage route, and C1A followed by C1B for the two-stage route, all filed on CORE. Paper filing of those forms is not accepted.

Who must register

Section 410 says the company that creates a charge is responsible for registering it. It also says anyone with an interest in the charge can use the registration procedure, and that their registration counts as if the company had done it. A person who registers in this way can recover from the company the registration fees they properly paid to the Registrar.

What happens if a charge is not registered

According to section 409, a charge not registered under either procedure is void against the liquidator and any creditor of the company. If the particulars omit required details for some property, the charge is void only as to that property. Where a charge becomes void, the secured money becomes payable immediately, though the underlying repayment contract remains.

The CRO says it cannot extend the 21-day deadline. It states that only the High Court can extend time, under section 417, and that the court order can then be submitted with an amended C1. Late applications are rejected, and amendments after the deadline are not accepted. Our guides to receivership in Ireland and voluntary liquidation show where secured creditors fit into those processes.

Priority between charges

Section 412 provides that where a rule of law ranks charges by when they were created, charges are instead ranked by when the Registrar receives the prescribed particulars; if the dates match, the receipt times on that day decide the order. The CRO page makes the same point and adds that it cannot guarantee priority to any particular charge. For two-stage filings, the CRO leaflet says the relevant date is when the first-stage form is received.

Section 412 also says particulars of negative pledges, floating-charge crystallisation events and restrictions on charged assets cannot be entered on the register, and their receipt has no legal effect. The exception is a negative pledge in a floating charge granted to the Central Bank to provide or secure collateral.

The CRO forms at a glance

The leaflet (online version last modified 4 June 2025) says the 21-day period for acquired property (C3, F9) runs from completion of the acquisition, and that failing to file an acquired-property charge on time is a category 4 offence, a summary offence with a fine of up to 5,000 euro (check the current figure on the official page). For a judgment mortgage the period runs from the creditor's receipt of notice from the Property Registration Authority, with receipt presumed on the third day after the notice is sent. The leaflet also says charges over cash, deposits, shares, bonds and fund units are generally excluded from registration; check the leaflet for the exact scope.

Signing, fees and certificates

The CRO page states that e-filing with a ROS signature is mandatory, and that two different individuals must sign, one for the company and one for the charge holder, each with a certificate in their own name. A solicitor cannot sign for both parties. As stated on that page, the C1/C1A fee is 40 euro, it is not refunded for rejected or returned forms, and a returned form can be corrected and resubmitted at no extra charge if still within the 21-day window. Check the current figure on the official page. Charge certificates are issued as digital PDFs, and the page says a registered certificate is conclusive evidence that the Act's requirements were met.

Satisfying and updating charges

When a debt is repaid, the C6 (full) or C7 (partial) records satisfaction. The CRO page says that if the chargee signs, the satisfaction is registered without notice under section 416(1); if only the company signs, the CRO notifies the charge holder, who has 21 days to lodge an objection. It also warns that a false declaration is a category 2 offence under section 871. The C17 can update the lender's details; the leaflet warns that failing to notify a change can lead to a charge being wrongly recorded as satisfied.

A practical checklist

Our suggestion: treat registration as a closing condition rather than an afterthought.

• Diarise the 21-day period, which section 409 measures from the creation of the charge (or, for the second stage, from receipt of the first notice).
• Confirm who is filing (company, lender or solicitor) and that ROS certificates are in the signatories' own names.
• Keep the digital certificate with the loan file.
• Check the register when reviewing a company's borrowings or taking over a client.
• File satisfactions promptly after repayment.

These are working suggestions, not legal requirements. The CRO page says it is advisable to obtain urgent professional advice if a presenter is in any doubt.

What the sources do not say

This guide does not set out sections 413 or 417; references to section 417 and to offence categories come from the CRO pages. The Irish Statute Book pages show no date and give the Act as enacted; we did not check for later amendment. The CRO pages carry the modification dates quoted above, and the official position may have changed since.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

How long does a company have to register a charge?

Section 409 and the CRO both refer to 21 days from creation of the charge for the one-stage route. For the two-stage route, the confirmation must follow within 21 days of the first-stage notice.

What happens if the 21 days are missed?

Under section 409, a charge not registered in time is void against the liquidator and any creditor of the company. The CRO says it cannot extend the deadline, and that only the High Court can extend time.

Who is responsible for registering?

Section 410 places the duty on the company that creates the charge, and also lets anyone with an interest in the charge register it and recover their fees from the company.

Does the order in which charges are created decide priority?

Under section 412, priority between charges follows when the Registrar receives the prescribed particulars, subject to the exceptions stated in that section.

Can charge forms be filed on paper?

Not for the registration forms. The CRO says C1, C1A and C1B must be filed on CORE and that a paper copy cannot be submitted. Check the CRO page for how the other forms, such as C6, C7 and C17, are filed.

Always check the current CRO guidance and the Act itself before filing a charge.