- ASIC commenced enforcement action against directors without DINs in June 2026
- New legislation gives ASIC power to disqualify non-compliant directors and deregister companies
- From 1 July 2027, companies must report director DINs to ASIC at every key corporate lodgement
- Directors must provide their DIN to the company within 7 days of appointment (from July 2027)
- Voluntary compliance now is far preferable to responding to an ASIC enforcement action
ASIC is no longer treating Director Identification Numbers (DINs) as a low-priority housekeeping matter. In June 2026, the regulator commenced enforcement action against directors who had failed to obtain a DIN. Parliament has now responded by passing legislation that gives ASIC stronger powers to pursue non-compliant directors — including the power to disqualify them from managing corporations.
If you are a director of an Australian company and you have not yet obtained your DIN, this article is your notice. The window to get ahead of this is now.
What Is a Director Identification Number (DIN)?
A Director Identification Number is a unique 15-digit identifier that every director of an Australian company must hold. DINs were introduced to combat illegal phoenix activity — where individuals wind up companies, leave creditors unpaid, and then reappear as directors of new companies to repeat the cycle.
Every current director of an Australian company was required to obtain their DIN by 30 November 2022. New directors appointed from 5 April 2022 onward were required to obtain a DIN before their appointment.
Despite the extended compliance window, ASIC has identified that a material number of directors still do not hold a DIN. In June 2026, it moved from issuing notices to commencing enforcement action.
What the New Legislation Changes
The Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Bill 2026, which has passed both Houses of Parliament, significantly strengthens the DIN regime in three key ways.
1. Companies Will Be Required to Report DINs to ASIC
From 1 July 2027, companies and registrable bodies must provide the DIN of each director to ASIC at key corporate reporting milestones. This means DIN compliance will now be embedded in routine ASIC lodgements — there is no longer any practical way to avoid the requirement.
2. ASIC Can Disqualify Non-Compliant Directors
The new legislation expands ASIC’s enforcement powers to include the ability to disqualify a director from managing corporations for failure to comply with the DIN regime. This is the same type of sanction ASIC uses when directors breach their director duties under the Corporations Act.
3. ASIC Can Deregister Companies That Provide False Information
Where a company provides false or misleading DIN information to ASIC, the regulator now has the power to deregister the company. For small to medium businesses, deregistration is an existential consequence.
Why ASIC Is Taking This Seriously Now
ASIC’s 2026 enforcement priorities signal that the regulator is no longer willing to tolerate ongoing non-compliance. The DIN regime is one of ASIC’s primary tools to eliminate illegal phoenixing — and the regulator intends to use every available power to pursue directors who have still not complied, nearly four years after the original deadline.
ASIC’s track record in 2026 speaks for itself. In April 2026, ASIC disqualified a Gold Coast director for the maximum five-year period for involvement in four failed companies owing more than $3 million to creditors. The message is clear: administrative non-compliance is now treated as seriously as substantive misconduct.
What Queensland Directors Must Do Now
Although the new reporting obligations do not commence until 1 July 2027, there are practical steps every director and company should take immediately.
Step 1: Confirm You Have Your DIN
Check that all current directors — including recently appointed alternate directors — hold a valid DIN. You can check and manage your DIN through the ABRS (Australian Business Registry Services) website.
Step 2: Update Your Director Onboarding Process
From 5 April 2022, new directors were required to obtain a DIN before appointment. Review your onboarding procedures to ensure this is captured as a condition of appointment, not a post-appointment afterthought.
Step 3: Prepare Your Governance Systems for 1 July 2027
From 1 July 2027, your company will need to lodge each director’s DIN as part of key ASIC reporting. If your company management systems do not currently capture DINs, begin updating them now. This includes your share registry, constitution and company secretarial practices.
Step 4: Get Legal Advice If You Have Not Complied
If you are a director who has not yet obtained a DIN, or if your company has not been recording DINs, obtain legal advice before ASIC’s enforcement attention reaches you. Voluntary compliance is always preferable to responding to an enforcement notice.
The Broader Picture: ASIC Enforcement in 2026
ASIC has doubled the number of new investigations it opened in 2025. Its enforcement posture in 2026 is the most active it has been in years. The DIN regime is part of a broader strategy targeting:
- Phoenix activity and serial company failures
- Directors who fail to pay employee entitlements and tax obligations
- Inadequate record-keeping by company officers
- Director-related transactions used to strip assets from struggling companies
For Queensland directors, the practical reality is clear: the compliance obligations that seemed like administrative formalities a few years ago are now enforcement priorities. ASIC has the tools, the intent, and the legislative mandate to pursue non-compliance.
If you have concerns about your DIN compliance position, your obligations as a director, or how ASIC’s expanded powers may affect your company, contact Boss Lawyers for practical, commercial advice.
Call Mark Harley on 1300 267 711.
This is general information only and is not legal advice. You should obtain professional advice specific to your circumstances.
