Director IDs for non-resident directors: the practical guide
Australia’s Director Identification Number (DIN) regime applies to every director of an Australian company, including non-resident directors. The obligation does not depend on residency; if a person is appointed as a director of an Australian Pty Ltd or registered foreign company, they need a DIN before the appointment takes effect. This catches every foreign director on the board of an Australian subsidiary.
The application process for non-resident directors is materially harder than the domestic process. Australian residents apply through myID (formerly myGovID), which uses a smartphone-based identity verification. Non-residents typically cannot access myID because it requires Australian-issued identity documents (Medicare card, Australian driver licence, Australian passport). For most foreign directors, the only available path is the paper-based application.
The paper application requires certified copies of identity documents, in many cases translated into English by an accredited translator. The required documents include a primary photo identification (passport), a secondary photo identification (national identity card or driver licence), and supporting evidence of residential address (utility bill, bank statement). Each document must be certified by a notary, lawyer, accountant, or police officer in the foreign jurisdiction. Different countries have different rules about who can certify; we have seen applications rejected because the certifying officer’s qualification was not recognised by ABRS.
The timeline is unpredictable. We have seen applications processed in as little as four weeks and as long as four months, depending on document acceptance, translation quality, and the responsiveness of the Australian Business Registry Services. The typical case is six to eight weeks. For a foreign group planning to appoint a non-resident director, the practical implication is that the DIN application must start at least six to eight weeks before the planned appointment date.
The most common failure modes are: documents certified by an officer not recognised in Australia, translations that are missing the translator’s certification, mismatched names between the passport and other documents (often due to maiden names or local-language ordering of names), and addresses that do not match the documentary evidence supplied. A cleanly compiled application is usually approved on first review. CoSec Partners coordinates non-resident DIN applications as part of foreign-owned subsidiary engagements.
Frequently asked questions
How long does a Director ID take for an overseas director?
Typically six to eight weeks, though we have seen four weeks at best and four months at worst depending on document acceptance, translation quality, and ABRS responsiveness. Any timetable that assumes a fast turnaround for a non-resident director is likely to slip.
Why can’t an overseas director use myID (formerly myGovID)?
Because myID verifies identity against Australian-issued documents such as a Medicare card, Australian driver licence, or Australian passport. A director with none of these cannot complete the digital process, and the paper application to ABRS is the remaining route.
What causes non-resident Director ID applications to be rejected?
Documents certified by an officer whose qualification Australia does not recognise, translations missing the translator’s certification, names that do not match across documents because of maiden names or local name ordering, and address evidence that does not match the documents supplied.
Can the appointment go ahead while the Director ID is pending?
No. A director appointed from 5 April 2022 must hold the number before the appointment takes effect, so the registration or appointment has to wait. Where timing is critical, the practical options are appointing a different director initially or using a shelf company and restructuring the board once the number issues. Either way, every person on the board must already hold a director ID; the overseas director can only be added once their number has been issued.
This article is general information only and does not constitute legal, financial, or tax advice. While we endeavour to keep content accurate and current, laws and regulations change frequently. For advice specific to your circumstances, please consult a qualified professional adviser. CoSec Partners Pty Ltd accepts no liability for actions taken based on this content.