DIN or out? What ASIC’s new enforcement powers mean for directors
ASIC's decision to enforce commencement action in June 2026 against directors who failed to obtain a director identification number (DIN) sent a clear message: the regulator is no longer treating DIN non-compliance as a low priority.
This message has now been reinforced by Parliament. The Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Bill 2026 has passed both Houses, strengthening the DIN regime by linking director identification numbers to ASIC's Companies Register and expanding ASIC’s enforcement powers. These expanded powers include the ability to disqualify non-compliant directors and deregister companies that provide false or misleading information.
Key takeaways
- From 1 July 2027, companies will need to report DINs to ASIC as part of key corporate reporting obligations.
- ASIC will have stronger enforcement powers, including the ability to disqualify directors and deregister companies in certain circumstances.
- Companies should review director onboarding processes and governance systems well before the new reporting requirements commence.
- With ASIC already taking enforcement action, DIN compliance should be treated as a genuine governance and compliance obligation.
Key changes
Companies must report DINs to ASIC
From 1 July 2027, companies and registrable bodies must provide the DIN of each director to ASIC at key reporting points, including:
registration of a new company;
appointment of a director;
notification of changes to director details; and
annual reporting.
This approach now integrates the DIN into ordinary corporate compliance workflows.
Directors must provide their DIN to the company
Directors must provide their DIN to the company within seven days of their appointment.
Where a newly appointed director does not yet hold a DIN, a grace period applies. A director has seven days to notify the company from the date the Registrar issues the DIN, after which the company has 14 days to lodge the DIN with ASIC.
ASIC can disqualify directors
Where ASIC reasonably believes a person has failed to apply for a DIN after being directed to do so by the Registrar, and the person has been given an opportunity to be heard, ASIC may disqualify that person from managing corporations for up to three years.
The new disqualification power, effective 1 July 2026, is intended to target individuals who have wilfully refused to apply for a DIN or have deliberately frustrated the process.
ASIC can deregister companies
The Bill also introduces a new administrative ground for deregistration where ASIC has reason to believe information provided by or on behalf of a company is materially misleading, false or deceptive, even if the company has otherwise met its administrative obligations.
Transitional arrangements
For existing directors whose DINs have not been lodged with ASIC by 1 July 2027, the company must lodge notice of the DIN before the earlier of:
- the end of the 28-day response period following the company’s next annual extract of particulars; or
- the end of the 28-day period following the next change in the director's personal details.
Non-compliance is a strict liability offence attracting a maximum penalty of 120 penalty units.
What you should do now
Although the new reporting requirements do not commence until 1 July 2027, companies should begin preparing now.
Boards, company secretaries and their advisors should consider:
- confirming that all current directors have obtained a DIN;
- reviewing onboarding procedures to ensure DINs are obtained and recorded at appointment; and
- ensuring governance systems are configured to report DINs to ASIC as part of standard lodgements.
Given ASIC's demonstrated willingness to enforce the relevant obligations, treating DIN compliance as an administrative afterthought is no longer a defensible position.
How we can help
The new regime introduces reporting obligations and strengthens ASIC’s enforcement powers.
If you would like advice on preparing for the new DIN requirements, reviewing your governance processes or understanding how the changes may affect your organisation, please contact our team.
Contacts
