Legal development

Enhancing Director ID Requirements

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    What you need to know

    • The Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Bill 2026 reforms the Director Identification Number (Director ID) regime under the Corporations Act, commencing 1 July 2027.
    • Transitional provisions require companies to lodge existing directors' Director IDs with ASIC within 2 weeks of their next review date or 28 days following the next change in personal details, whichever is earlier.
    • Companies and registrable bodies must provide Director IDs to ASIC as part of standard registration and reporting processes, including at registration, appointment, change of details, and cessation.
    • Directors will be required to provide their Director ID to their company within 7 days of appointment, alongside other personal details such as name and address.
    • ASIC will be able to publish Director ID information on its registers for the first time.
    • ASIC gains a new power to disqualify a person from managing corporations for up to three years if they fail to apply for a Director ID when directed by the Registrar.

    What you need to do

    • Audit director records now: Confirm that all current directors and alternate directors hold a valid Director ID. Any directors without one should apply immediately to avoid strict liability offences or disqualification risk from 1 July 2027.
    • Update governance processes: Amend appointment processes, board checklists, and director consent forms to capture and record Director IDs as a mandatory field alongside existing personal details.
    • Update ASIC lodgement systems: Ensure that systems and templates used for ASIC forms (registration, appointment, change of details, cessation) are updated to include Director ID fields before commencement.
    • Plan for transitional deadlines: Identify any current directors whose Director IDs have not been lodged with ASIC and prepare to lodge that information promptly after 1 July 2027, noting the tight timeframes (2 weeks from next review date or 28 days from next change in personal details).
    • Brief directors on new obligations: Make directors aware of the 7-day notification requirement on appointment and the consequences of non-compliance, including strict liability offences and potential disqualification.

    1. Enhancing Director ID Requirements

    Key reforms to the Director Identification Number regime

    1.1 Introduction

    The Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Bill 2026 (the Bill) introduces significant reforms to the Director Identification Number (Director ID) regime established under the Corporations Act 2001 (Cth) (the Corporations Act). The Director ID portions of the Bill commence on 1 July 2027.

    The Director ID regime has applied since November 2021 as part of broader reforms to strengthen corporate transparency and combat illegal phoenix activity.

    The Bill enhances the Director ID regime by increasing its requirements and enforcement. In particular, it facilitates the inclusion of Director ID information on ASIC’s Companies Register. To support this, companies and registrable bodies will be required to provide the Director ID of each director to ASIC as part of standard corporate registration and reporting practices.

    1.2 Practical Implications for Companies and Directors

    Companies, registrable bodies, and their directors should be aware of the following practical implications arising from these reforms:

    • Directors: All directors and alternate directors should ensure they hold a valid Director ID. Those who do not should apply immediately. From 1 July 2027, directors will be required to provide their Director ID to their company within 7 days of initial appointment. Failure is a strict liability offence.
    • Companies: Companies should update their internal governance processes to capture and record each director’s Director ID alongside existing personal details. Systems for ASIC lodgements should be updated to include Director IDs in all relevant forms (registration, appointment, change of details, cessation).
    • Transitional compliance: Companies with current directors whose Director ID has not yet been lodged with ASIC should plan to lodge that information promptly upon commencement (1 July 2027), noting the tight transitional deadlines (2 weeks following the next review date or 28 days following the next change in personal details, whichever is earlier).
    • Disqualification risk: Directors who wilfully refuse to apply for a Director ID or deliberately provide deficient applications face the risk of disqualification from managing corporations for up to three years.

    1.3 Comparison of Key Features: New Law and Current Law

    New Law
    Current Law
    Each director or alternate director must have a Director ID, given by the Registrar.
    Each director or alternate director must have a Director ID, given by the Registrar (unchanged).
    Each director must provide their Director ID to their company, along with other personal details.
    No requirement that a director provide their Director ID to their company (though they must provide other personal details).
    Companies and other registrable bodies must provide Director IDs to ASIC during standard reporting processes.
    No requirement that a company or other registrable body provide Director IDs to ASIC.
    ASIC can publish Director ID information on its registers.
    ASIC cannot publish Director ID information on its registers.
    The Registrar has an express power to correct Director ID information.
    The Registrar lacks an express power to correct Director ID information.
    ASIC can disqualify directors for not applying for a Director ID when directed by the Registrar.
    ASIC cannot disqualify directors for not obtaining a Director ID.
    Infringement notices for Director ID contraventions issued by ASIC under Part 9.4AB of the Corporations Act.
    Infringement notices issued by the Registrar or their staff under section 1272F of the Corporations Act.

    1.4 New Obligations: Providing Director ID Information to ASIC

    (a) Obligation on directors to provide Director ID to their company

    Under the amended regime, a director’s "personal details" will expressly include their Director ID, alongside their name, address, and birth details.

    A director is required to provide their Director ID to the company within 7 days of their initial appointment, unless they have previously provided that information to the company. Failure to comply on time continues to be a strict liability offence.

    The Bill provides grace periods for both companies and directors in respect of newly appointed directors who do not yet have a Director ID number. This addresses "appointed from the floor" scenarios:

    • Director grace period: A director who does not yet have a Director ID at the time of appointment must notify their company of their Director ID within 7 days of being given the Director ID by the Registrar.
    • Company grace period: The company’s grace period to lodge the Director ID with ASIC is 14 days following the provision of the Director ID number to the director.

    (b) Obligation on companies to provide Director IDs to ASIC

    Companies and other registrable bodies must now provide ASIC with the Director ID of each director or alternate director at the following:

    • application to register a new company or body;
    • appointment of a new director;
    • change to the personal details of an existing director; and
    • when a person stops being a director.

    (c) Publication on ASIC’s registers

    Director ID information will also appear as part of ASIC’s annual extract of particulars and return of particulars processes.

    1.5 New ASIC Disqualification Power

    The Bill confers on ASIC a new power to disqualify a person from managing corporations for up to three years if that person fails to apply for a Director ID when directed to do so by the Registrar.

    The Bill repeals the Registrar’s power to issue infringement notices under the Director ID regime and grants ASIC that power. ASIC may issue an infringement notice for a contravention of the requirements for eligible officers to have a Director ID and to apply for a Director ID when directed to do so by the Registrar.

    1.6 Consequences of Non-Compliance

    Failure by a director or their company or registrable body to comply with the new requirements of the Director ID regime may attract an infringement notice or penalty consistent with the existing law (as amended). In particular:

    • A company failing to lodge personal details of its directors (which now includes their Director ID) commits a strict liability offence.
    • A director who fails to provide their personal details (including Director ID) to the company commits a strict liability offence.
    • ASIC may refuse to register a company or body if required information (including Director ID) is not included in its application for registration.

    (a) Transitional provisions for existing directors

    The Bill includes transitional arrangements to support a smooth transition to the new corporate reporting requirements. From 1 July 2027:

    • Companies: For current directors and alternate directors of companies whose Director ID information has not been lodged with ASIC, the company must lodge notice of their Director ID with ASIC before the end of the 2 week period following the company’s next review date, or the end of the 28 day period following the next change in the person’s personal details, whichever is earliest. Failure to do so is an offence, punishable by a maximum fine of 120 penalty units.
    • Registered bodies: For current directors of a registered body corporate whose Director ID information has not been lodged with ASIC, the body corporate must lodge notice within one month. Failure to do so is an offence, subject to 20 penalty units.

    Author: Miriam Kleiner, Partner.

    The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
    Readers should take legal advice before applying it to specific issues or transactions.

    Ashurst Perkins Coie practises law in Singapore through Ashurst Perkins Coie UK LLP and also maintains a Formal Law Alliance with ADTLaw LLC, known as Ashurst ADTLaw.

    Ashurst Perkins Coie UK LLP is regulated in Singapore by the Attorney-General's Chambers of Singapore and is registered under the LLP Registration Act, Registration No. LL0701574M.

    Ashurst ADTLaw is a Formal Law Alliance licensed and regulated by the Legal Services Regulatory Authority of Singapore under number LSRA/FLA/2017/00001. ADTLaw LLC is a limited liability company registered in Singapore under number 201324473R, licensed and regulated by the Legal Services Regulatory Authority of Singapore under number LSRA/LLC/2013/00191.