Director identification numbers: practical lessons from the 2026 reforms

Since the director identification number (DIN) regime commenced in November 2021 most Australian companies have completed the initial implementation. Attention has now shifted from obtaining DINs to embedding DIN compliance within ordinary governance processes. The Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Act 2026 reinforces that shift by strengthening ASIC's enforcement powers and integrating DINs more closely into Australia's corporate registry framework.

Practical implications

For many Australian companies the initial DIN rollout is complete. The practical challenge is no longer obtaining DINs. It is ensuring that DIN compliance is embedded into director appointments, succession planning and ASIC reporting processes.

In our experience, DIN issues now arise most commonly:

• when appointing overseas directors;
   
• in cross-border acquisitions with compressed completion timetables;
   
• during group restructures involving multiple new entities;
   
• during IPOs and pre-listing restructures;
   
• where private equity or venture capital investors appoint nominee directors at completion; and
   
• when companies discover historical governance gaps during due diligence.

For governance teams, the practical effect of the 2026 reforms is that DIN compliance becomes part of ordinary corporate secretariat processes rather than a one-off implementation project. Appointment documentation, board onboarding, ASIC lodgments and periodic governance reviews should all include DIN verification.

What is a DIN?

A DIN is a unique 15-digit identifier used to verify the identity of an individual director and is permanently assigned to the director.

In practice, DINs have become another core governance identifier that companies must capture and maintain as part of their corporate records. While directors generally obtain only one DIN during their lifetime, companies will increasingly need processes to verify, record and report DINs as part of routine corporate administration.

The DIN regime is administered by the Australian Business Registry Services (ABRS), which is overseen by the Australian Taxation Office (ATO). 

On 30 June 2026, the Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Act 2026 passed both Houses of Parliament. The Act amends the Corporations Act 2001 (Cth) and related legislation to enhance the DIN regime, strengthen ASIC’s powers to administer business registers and stabilise the broader registry architecture following the cessation of the Modernising Business Registers program. 

Who must apply?

A DIN must be obtained by a director or alternate director of:

• a company;
   
• a registered Australian body that is a body corporate; or
   
• a registered foreign company that is a body corporate,
   
• in each case which is registered under the Corporations Act. 

This includes Australian companies that are responsible entities and registered charities, even if they are also registered under other laws. The DIN requirement applies to formally appointed directors and acting alternate directors. It does not extend to a person merely because they may be treated as a shadow or de facto director under the broader definition of “director” in the Corporations Act.

Lessons from practice

1. Start early for overseas directors: paper applications, certification requirements and international postage continue to create timing risk. In competitive transactions, leaving a foreign director's application until immediately before completion can delay board appointments or require changes to completion mechanics.
    
2. Treat DINs as part of director onboarding: many organisations now include DIN verification within director onboarding checklists alongside conflict disclosures, deeds of access and insurance arrangements.
    
3. Build DIN verification into transaction planning: where completion requires appointment of new directors, check DIN status early in due diligence rather than assuming it can be addressed immediately before signing or completion.
    
4. Keep a central register: large corporate groups increasingly maintain an internal register recording directors' DINs (with appropriate security) so ASIC lodgements can be completed promptly.
    
5. Don't assume existing directors are compliant: governance reviews occasionally identify long-serving directors who never completed the original application process or whose details require updating.

DINs in M&A transactions

Where completion involves appointment of bidder nominees, foreign investors or new holding company directors, DIN timing should be included in transaction planning. In cross-border transactions, obtaining foreign directors' identification documents and certifications can take considerably longer than expected.

What companies should do now

Companies should consider whether they:

• have verified every current director holds a DIN;
   
• require DIN confirmation before accepting any new appointment;
   
• have updated director onboarding procedures;
   
• have processes for obtaining DINs from overseas directors sufficiently early;
   
• have systems to meet the 2027 ASIC reporting requirements; and
   
• periodically review DIN records as part of broader governance compliance. 

Prospective directors - applying before appointment

A person appointed as a director on or after 1 November 2022 must obtain a DIN before their appointment. Directors can apply up to 12 months in advance of being appointed. In our experience, timing rather than complexity is the real issue. Australian resident directors who can apply online generally receive their DIN almost immediately. By contrast, foreign directors often require significantly longer, because of certification requirements, international postage and paper-based processing.

Applying for a DIN

The application process differs depending on whether the applicant is an Australian resident or overseas, and whether the application is made online, by phone or by paper. Australian resident directors can generally apply online using myID, while overseas directors currently apply by paper application.

Applicants are responsible for verifying their own identity and will need to provide appropriate identification documents. The identity requirements, certification rules and application procedures differ depending on the applicant's circumstances and are updated periodically by the Australian Business Registry Services (ABRS).

Directors should consult the current ABRS guidance before commencing an application, particularly where they are applying from overseas or relying on certified or translated identity documents.

For overseas directors, we recommend commencing the application process as early as possible. In our experience, certification requirements, translation requirements and international postage can materially affect transaction timetables.

Detailed guidance on eligibility, identity requirements, acceptable certification and current application procedures is available from the Australian Business Registry Services (ABRS).

What to do after acquiring a DIN

Once the DIN is issued, the director should provide it to each company of which they are a director. Companies are required to keep each director’s DIN on file, as DINs are now required when lodging relevant forms with ASIC (such as Form 201, Form 484 and Form 362A). 

Companies should treat DINs as part of standard governance records alongside directors' consents, interests, deeds of access and insurance records.

From 1 July 2027, further obligations will apply, including a requirement for directors to provide their DIN to the company within seven days of appointment. Companies will also be required to report DINs to ASIC as part of standard corporate registration and reporting. This includes during standard corporate registration and reporting, notification of director appointments and cessations, changes to personal details and annual reporting. A limited grace period will apply in the event that a director does not yet hold a DIN at the time of their appointment. In that circumstance, the director will have seven days from receipt of the number, and the company will then have 14 days from that point, to lodge the DIN with ASIC. Over time, the companies register will begin to display whether or not a company has appropriately provided their DINs.

Penalties for non-compliance

Penalties for non-compliance include civil and criminal penalties. Accessorial liability may also arise. Penalties are also associated with conduct that would undermine the DIN regime. For example, there are criminal penalties for deliberately providing false identity information to the ABRS, intentionally providing a false DIN to a government body or relevant body corporate, or intentionally applying for multiple DINs. From 1 July 2026, the Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Act 2026 repeals the Registrar’s infringement notice powers, with ASIC confirmed as the sole enforcement agency for the DIN regime. Also from 1 July 2026, ASIC has a new power to disqualify a person from managing corporations for up to three years if they fail to apply for a DIN when directed by the Registrar. This power will apply where a director has wilfully refused to apply or has applied in a manner calculated to result in refusal.

ASIC has now obtained several convictions against directors for failing to hold a DIN, with total fines exceeding A$40,000. These prosecutions demonstrate that ASIC regards the regime as an active compliance obligation rather than a purely administrative requirement. Directors and companies should therefore treat DIN compliance in the same way as other core governance obligations.

Although DIN breaches might once have been viewed as largely administrative, the legislative amendments demonstrate a clear policy shift. Failure to comply may now expose directors not only to penalties but, in serious cases, to disqualification from managing corporations. That places DIN compliance alongside other core governance obligations that boards should treat as routine rather than optional.

Key changes under the Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Act 2026

The 2026 Act is structured across three Schedules, with Schedule 1 directly affecting the DIN regime. The key changes are as follows:

New ASIC disqualification power (from 1 July 2026).

ASIC may disqualify a person from managing corporations for up to three years where they fail to apply for a DIN when directed by the Registrar, including where they have wilfully refused to apply or applied in a manner calculated to result in refusal. This represents a significant escalation from administrative enforcement and demonstrates Parliament's intention that deliberate DIN non-compliance may justify excluding individuals from corporate management.

Consolidated enforcement (from 1 July 2026).

The Act repeals the Registrar’s infringement notice powers. ASIC is confirmed as the sole enforcement agency for the DIN regime.

Registrar corrections power (from 1 July 2026). 

The Act gives the Registrar express power to authenticate, verify, validate, store, correct, integrate or link information it holds. This enables DIN records to be kept accurate without imposing additional compliance burdens on directors. 

Mandatory DIN reporting to ASIC (from 1 July 2027). 

Companies and registrable bodies will be required to provide DINs to ASIC as part of standard corporate registration and reporting, including applications to register a company, notification of director appointments and cessations, changes to personal details and annual reporting.

Directors must provide their DIN to the company (from 1 July 2027). 

Directors will be required to give their DIN to the company within seven days of appointment. A grace period applies where the director does not yet hold a DIN: the director has seven days from receipt of the DIN and the company then has 14 days to lodge with ASIC.

These reforms mean DIN compliance will increasingly be tested through ordinary ASIC filings rather than isolated compliance reviews.

The 2026 reforms confirm that the director identification regime has moved beyond a one-off implementation exercise. For boards and company secretaries, the focus should now be on embedding DIN compliance into governance systems, transaction planning and director appointment processes. Organisations that do so are unlikely to encounter difficulty. Those that continue to treat DINs as a standalone administrative requirement may increasingly find compliance gaps exposed through routine ASIC reporting and enforcement activity.

See the ABRS website for further information and developments.