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FeaturesBlockManOSUpdated March 11, 2026

Known Gap: CRO Filing Reminder & OMC Company Compliance Tracking

Known Gap: CRO Filing Reminder & OMC Company Compliance Tracking

Status: Incomplete — High Severity This page documents the current state and known gaps in CRO filing reminder and OMC company compliance tracking as of v1.0.18.

Overview

Owners' Management Companies (OMCs) incorporated under the Companies Act 2014 are required to file annual returns with the Companies Registration Office (CRO), including B1 and B2 forms. Property management agents are also subject to PSRA (Property Services Regulatory Authority) licensing requirements with defined renewal cycles.

The platform is designed to automate compliance deadline tracking and proactively alert agents to approaching obligations. As of v1.0.18, this functionality is partially implemented.

What Currently Works

OMC Details — Date Fields

Each OMC record (omcDetails) stores the following CRO-relevant fields:

FieldDescription
croAnnualReturnDueThe date by which the OMC must file its next annual return with the CRO
croLastFiledDateThe date on which the most recent annual return was filed

These fields can be viewed and edited via the OMC record in the platform.

General Compliance Checklist

A compliance checklist is available per development, covering a broad set of statutory and operational obligations. CRO filing is listed as a checklist item.

Known Gaps

1. No Automated CRO Reminder Notifications

The compliance-deadline-alerts background job processes compliance deadlines but does not currently integrate with croAnnualReturnDue or croLastFiledDate. As a result:

  • No email or in-app notifications are sent as CRO filing deadlines approach.
  • Agents must manually monitor the croAnnualReturnDue field on each OMC record.

Workaround: Review OMC records manually on a regular schedule and cross-reference against CRO filing calendars.

2. No CRO Filing Workflow

There is no guided workflow within the platform for managing the end-to-end CRO annual return process. The following steps are not supported:

  • Initiating a filing task for a specific OMC
  • Recording the preparation and review of B1/B2 forms
  • Logging submission confirmation and CRO acknowledgement
  • Updating croLastFiledDate automatically upon completion

Workaround: Manage the CRO filing process externally and update croLastFiledDate manually in the OMC record after submission.

3. No Dedicated B1/B2 Form Tracking Page

Beyond the general compliance checklist entry, there is no dedicated page for tracking the status of CRO form submissions per OMC. Specifically:

  • No filing history log per OMC
  • No per-filing status (e.g. Pending, Submitted, Accepted, Overdue)
  • No distinction between B1 (annual return) and B2 (change of registered office/details) filings

Workaround: Maintain a separate record of filing history outside the platform.

4. No PSRA Licence Expiry Alerting

PSRA licence data is not currently tracked in the data model, and no alerting exists for upcoming licence expiry. Agents must independently monitor their PSRA licence renewal dates.

Workaround: Track PSRA licence expiry dates manually and set external calendar reminders.

Planned Resolution

The following enhancements are planned to close these gaps:

Phase 1 — Automated CRO Reminders

  • Extend compliance-deadline-alerts to consume croAnnualReturnDue from omcDetails.
  • Send configurable reminder notifications at 60, 30, and 14 days before the due date.
  • Send an overdue alert if the due date passes without a recorded filing.

Phase 2 — CRO Filing Workflow

  • Add a CRO Filings module to each OMC record.
  • Support creation of filing tasks with status tracking (Draft → In Review → Submitted → Confirmed).
  • Auto-populate croLastFiledDate on confirmation.

Phase 3 — B1/B2 Tracking Page

  • Dedicated CRO Filings tab per OMC showing full filing history.
  • Filter and sort by form type, status, and due date.
  • Export filing records for audit purposes.

Phase 4 — PSRA Licence Tracking

  • Add psraLicenceNumber, psraLicenceExpiry, and psraLicenceStatus fields to the relevant agent/management company record.
  • Integrate PSRA expiry into the compliance-deadline-alerts job.
  • Surface PSRA licence status in the compliance dashboard.

Irish Regulatory Context

ObligationGoverning BodyLegislation
Annual Return (B1)Companies Registration Office (CRO)Companies Act 2014, s.343
Change of Details (B2)Companies Registration Office (CRO)Companies Act 2014
Property Management LicenceProperty Services Regulatory Authority (PSRA)Property Services (Regulation) Act 2011

Failure to file CRO annual returns on time results in late filing penalties and potential strike-off of the OMC. PSRA licence lapses prevent agents from legally providing property management services.

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