Director ID enforcement: what ASIC is doing in 2026

The Director Identification Number (DIN) regime has moved from education to enforcement. ASIC has been prosecuting directors without a director ID since 2024. By mid 2026 it had prosecuted 11 directors, and in May 2026 two NSW directors were each fined $10,000. Not having a director ID when required is a criminal offence carrying up to 60 penalty units ($21,840 from 1 July 2026) and is also a civil penalty provision, and applying for more than one director ID or misrepresenting one can lead to imprisonment.

Every person who serves as a director of an Australian company, registered foreign company, or Aboriginal and Torres Strait Islander corporation must hold a DIN. There are no exceptions for dormant companies, trustee companies, or single-director entities. The DIN is a personal identifier tied to the individual, not to any specific company. It remains valid for life, even if the person ceases to be a director. A person who serves as director of multiple companies only needs one DIN.

The DIN application must be made personally by the individual. It cannot be done by an agent, accountant, or company secretary on the director’s behalf. The process normally uses myID (formerly myGovID) to verify identity; directors who cannot use myID, including most overseas directors, apply by phone or paper form to ABRS. Using myID, the director needs to download the myID app, verify their identity using their passport, driver’s licence, or Medicare card, and then apply for the DIN through the Australian Business Registry Services (ABRS) portal. Once verified, the DIN is issued immediately.

Directors appointed from 5 April 2022 onwards must obtain their DIN before their appointment takes effect. A company should not appoint a new director until they have received their DIN. For accounting firms that regularly establish new companies, this is a critical workflow consideration. The director must have their DIN before they are appointed, which for a new company means before the registration application is lodged. ASIC does not yet check director IDs on lodgement, but it will start collecting them from 1 July 2027, and appointing a director without one exposes the director to prosecution.

The most common issue we encounter is existing directors who were required to apply by 30 November 2022 but have not done so. Many are unaware of the requirement, particularly directors of dormant entities, SMSF trustee companies, or companies held within family group structures where the director role is seen as administrative rather than active. If your client is a director and does not have a DIN, they are technically in breach of the law right now.

Not having a director ID when required is an offence under section 1272C of the Corporations Act with a maximum penalty of 60 penalty units ($21,840 at the $364 penalty unit that applies from 1 July 2026). It is also a civil penalty provision, so ASIC can seek much larger civil penalties. Failing to apply when directed by the Registrar (section 1272D) is a further 60 penalty unit offence. Applying for more than one director ID, or misrepresenting a director ID, carries up to 12 months imprisonment.

From 1 July 2027 companies will have to give ASIC the director ID of each director, and the companies register will progressively show whether this has been done, so missing director IDs will become much easier to detect.

We recommend that every accounting firm conduct a DIN audit across their entire client base. For each entity, confirm that every current director holds a valid DIN. Where they do not, assist them in applying through myID immediately. The application process takes approximately 15 minutes for a director with a verified myID. For directors who have difficulty with the digital process, particularly older directors or overseas-based directors, the ABRS helpline can assist with alternative verification methods.

CoSec Partners verifies DIN status for all directors as part of our onboarding process and as part of every company registration. We flag any missing DINs before they become an enforcement issue and can assist your clients in understanding the application process.