13/12/2025 • 18 min read
Director IDs A–Z: Australian 2025 Guide
Director IDs A–Z: Australian 2025 Guide
Director IDs are a permanent, unique identifier that eligible directors must obtain under Australia’s director identification number regime to help prevent unlawful “phoenixing” activity and improve the integrity of corporate registers; in practice, Australian accounting firms must ensure each client’s directors (including many trustees of corporate trustees) apply via the Australian Business Registry Services (ABRS) and that identity verification is completed correctly and on time, because failures can expose directors to civil and criminal penalties under the Corporations Act 2001 and the director ID legislation.
What is a director ID (DIN) in Australia?
A director ID is a unique 15-digit identifier a person applies for once and keeps forever, even if they change companies, resign, move interstate, change their name, or become a director again later.
- ASIC registry integrity and director traceability
- Anti-phoenixing enforcement
- ATO and Treasury-led compliance initiatives (director ID is administered by ABRS, not the ATO, but it supports whole-of-government compliance)
- Australian Business Registry Services (ABRS): Director ID guidance, application pathways, identity verification requirements
- Corporations Act 2001: Enforcement framework, including penalties
- Treasury Laws Amendment (Combating Illegal Phoenixing) Act 2020 and related instruments establishing and amending the director ID regime (administered within the Commonwealth registry framework)
Who must apply for a director ID?
A person must apply if they are an “eligible officer” appointed as a director (or equivalent) of certain entities registered under the Corporations Act.
- Directors of Australian companies (including proprietary companies and public companies)
- Directors of registered Australian bodies and foreign companies registered under the Corporations Act
- Directors of corporate trustees (common in SME groups, family trusts, and SMSF service chains where a company acts as trustee)
Common practice trap: clients often focus on the trading entity and overlook the corporate trustee. That is where many compliance gaps occur, particularly in family group structures.
Which roles are excluded or commonly misunderstood?
Some roles are frequently confused with “director” for director ID purposes. The correct treatment depends on legal appointment status, not job title.
- Company secretary: not automatically captured unless also appointed as a director
- “Shadow” or “de facto” directors: may be captured depending on facts and legal characterisation; formal advice should be considered for higher-risk matters
- Sole traders and partnerships: not captured unless there is a company acting in the structure
- Individual trustees (not corporate trustees): director ID does not apply because there is no company director role
Professional note: Where there is uncertainty (for example, complex governance, nominee arrangements, or disputes), consideration should be given to obtaining legal advice. The accounting file should document the basis for conclusions.
When did director IDs start and what are the deadlines now (as of December 2025)?
Director ID obligations commenced in stages, with deadlines depending on when the director was appointed.
- Most existing directors should already have a director ID.
- New directors generally must apply before appointment (or immediately upon appointment under current rules and ABRS guidance, depending on appointment circumstances).
- Firms should treat “director ID obtained” as a pre-appointment or immediate appointment condition in governance checklists.
Because deadlines and transitional rules have changed over time, the most reliable source for “current deadline for a specific appointment date” is ABRS director ID guidance. Practices should link their internal procedures to the ABRS deadlines page and retain a file note evidencing the check.
How does a director apply for a director ID?
A director ID application is a personal application; it cannot be delegated to an accountant, registered agent, or lawyer to complete on the director’s behalf, because identity verification is central to the regime.
- Director gathers identity documents (myGovID/strong identity where applicable).
- Director logs in and applies through ABRS (online is the primary channel).
- Director receives the director ID (retain evidence securely).
- Director provides the director ID to relevant companies and advisers for record-keeping.
- A short explainer of why it’s required
- The ABRS application link
- A checklist of identity documents
- Instructions for directors who cannot access online services (ABRS offers alternative pathways)
What identity documents and verification are required?
ABRS requires identity verification to a standard consistent with Commonwealth digital identity settings. The exact document combinations and verification pathway are set out on ABRS guidance and may be updated.
- Do not “store more than you need” (privacy risk).
- Store evidence that the director ID has been issued (for example, screenshot/PDF confirmation provided by the director) rather than copies of identity documents, unless there is a clearly documented lawful need.
Consideration must be given to the Privacy Act 1988, your firm’s privacy policy, and information security controls when collecting and storing director IDs.
What are the penalties for not having a director ID?
Non-compliance can expose directors to significant civil and criminal penalties. It should be noted that regulators have emphasised enforcement as part of anti-phoenixing strategies.
- It is a personal legal obligation.
- “I didn’t know” is not an adequate control; firms should evidence that they informed directors.
- Repeated non-compliance can become a broader governance red flag relevant to ASIC and ATO risk profiling.
- Corporations Act 2001 penalty framework
- Director ID legislative regime and ABRS compliance statements and guidance
How should accounting practices capture director IDs in workflows?
Accounting practices should treat director IDs as a standing compliance data point, similar to TFN/ABN verification and ASIC company statement checks, but with higher personal identity sensitivity.
- Client onboarding: ask for director IDs for all directors of all companies in the group (including corporate trustees).
- Annual compliance: confirm director IDs remain recorded and correct (director ID does not change, but records can be missing).
- Entity health check: reconcile ASIC company statements to your internal director register; identify new appointments needing director IDs.
- Working papers: include director ID status in the permanent file and annual compliance checklist.
- A family trust has a corporate trustee Pty Ltd.
- The trading business is also a company.
- Two family members are directors of both companies.
- If the practice only checks the trading company, the corporate trustee directors may be missed, creating avoidable exposure.
How do director IDs interact with ASIC records and ATO compliance?
Director IDs are administered by ABRS and are part of the broader Commonwealth business registry ecosystem. While the ATO is not the issuing body, the regime supports whole-of-system integrity and cross-agency compliance initiatives.
- Better traceability of director histories across failed entities (anti-phoenixing)
- Greater likelihood that “director-level” issues are escalated in integrity reviews
- Increased need for clean governance documentation for clients with multiple entities and frequent director changes
What should you tell clients about privacy and storing director IDs?
A director ID is sensitive personal information. Practices should collect and store it securely, restrict staff access, and avoid unnecessary duplication.
- Record the director ID in a secure practice system with role-based access.
- Retain evidence of the ID being provided (for audit trail).
- Avoid collecting copies of identity documents unless required for a specific engagement purpose and the director has provided informed consent.
How do you fix a missing director ID or incorrect records?
The remediation approach is administrative but should be documented.
- Confirm current director appointments from ASIC records and internal registers.
- Identify which individuals are required to hold a director ID.
- Instruct each director to apply via ABRS (they must do it personally).
- Obtain confirmation of the issued director ID and update the permanent file.
- Update company governance registers and annual compliance checklists.
- The advice provided
- The risk and potential penalties explained
- The engagement limitations (if any) and escalation actions taken
Is MyLedger relevant to director ID compliance for accounting firms?
MyLedger is not a director ID issuing tool; director IDs are issued by ABRS. However, MyLedger (by Fedix) is highly relevant to the operational reality that director ID compliance sits alongside BAS, GST, year-end reconciliations, and working papers.
- Automated bank reconciliation: MyLedger = 10–15 minutes per client, typical manual workflows in other systems = 3–4 hours (around 90% faster).
- Working papers automation: MyLedger = automated working papers (including Division 7A automation and BAS reconciliation), many alternatives = manual Excel-based processes.
- ATO integration accounting software (practice workflow): MyLedger = deep ATO portal integration for statements, transactions and due dates, competitors = commonly limited ATO connectivity in the accounting workflow layer.
- Pricing model for firms: MyLedger = estimated $99–199/month unlimited clients (free during beta), Xero/MYOB-style models = commonly per-client subscription costs.
The practical outcome is that governance tasks like director ID register upkeep stop being “the thing you do at midnight” because compliance capacity is restored.
How does MyLedger compare with Xero, MYOB, and QuickBooks for practice efficiency?
MyLedger is designed for Australian accounting practices, while Xero, MYOB and QuickBooks are primarily general small business ledgers; the difference matters because director ID compliance work sits inside a broader practice system of recurring compliance tasks.
- Reconciliation speed: MyLedger = 10–15 minutes per client, Xero/MYOB/QuickBooks = commonly 3–4 hours in exception-heavy files.
- Automation level: MyLedger = AI-powered reconciliation with around 90% auto-categorisation, Xero/MYOB/QuickBooks = rules plus higher manual review burden.
- Working papers: MyLedger = automated working papers (Division 7A, depreciation, BAS/ GST reconciliation), Xero/MYOB/QuickBooks = typically separate working paper tools or manual Excel workflows.
- ATO integration accounting software: MyLedger = direct ATO portal integration (statements, transactions, due dates), competitors = generally limited or indirect ATO workflow coverage.
- Firm pricing scalability: MyLedger = designed for unlimited-client firm economics, competitors = per-client subscription scaling pressure.
For firms seeking an “Xero alternative” specifically to reduce compliance labour, the differentiator is that MyLedger automates what other platforms still require staff to do manually.
What is the A–Z checklist for director ID work in an accounting practice?
A practical A–Z approach is to standardise director ID handling across onboarding, annual compliance, and change events.
- A – ABRS check: Use ABRS guidance as the authoritative process reference for each engagement.
- B – Beneficial structure review: Map all entities (trading companies and corporate trustees).
- C – Company statement reconciliation: Compare ASIC records to your internal director register.
- D – Director appointment events: Trigger an “apply for director ID” task at appointment.
- E – Evidence retention: Store confirmation securely; avoid excess identity data.
- F – File note discipline: Record advice given and dates of director confirmations.
- G – Governance pack: Provide a director ID instruction sheet to directors.
- H – High-risk flags: Multiple failed entities, frequent changes, overdue lodgments.
- I – Identity pathway support: Guide directors to the correct ABRS channel (online/alternate).
- J – Joiners/leavers: Update director registers immediately upon changes.
- K – Key-person dependency: Avoid one staff member holding all director ID knowledge.
- L – Lodgment workflow alignment: Tie director ID checks to BAS/ITR year-end steps.
- M – Minutes and resolutions: Ensure appointments/resignations are properly documented.
- N – New client triage: Ask early; do not wait until year-end.
- O – Ongoing monitoring: Annual confirmation as part of compliance checklist.
- P – Privacy controls: Restrict access; apply least-privilege and encryption controls.
- Q – Quality review: Reviewer confirms director IDs captured for each relevant entity.
- R – Rectification process: Clear steps when director IDs are missing.
- S – Staff training: Standard scripts and escalation points.
- T – Trustee focus: Corporate trustee directors are commonly missed—always check.
- U – Update registers: Maintain a central director ID register per group.
- V – Version control: Keep a record of when director ID status was last verified.
- W – Working papers integration: Include director ID checklist in permanent file.
- X – Cross-entity consistency: Same person, one director ID, multiple roles—record once, link everywhere.
- Y – Year-end governance review: Add to annual “corporate health” checklist.
- Z – Zero surprises policy: Make director ID part of standard engagement letters and onboarding.
What are common director ID pitfalls and how do you avoid them?
The most common pitfalls are process failures, not technical complexity.
- Assuming the accountant can apply on behalf of the director (they cannot).
- Missing corporate trustees in group structures.
- Not capturing director IDs during urgent new company setups.
- Poor privacy controls (over-collection of identity documents).
- No documented evidence that advice was provided.
- Standardised onboarding checklist
- Annual confirmation in working papers
- A single “group register” view of all directors across entities
- Secure storage and restricted access
Next Steps: How Fedix can help your firm stay compliant and efficient
Director ID compliance is easiest when your practice has time and clean workflows. Fedix helps create that capacity by reducing core processing time.
- Automated bank reconciliation that reduces 3–4 hours to 10–15 minutes per client
- Automated working papers to reduce Excel-heavy compliance work
- Deep ATO-integrated workflows that align with Australian BAS/IAS/ITR cycles
- Firm-friendly economics designed for unlimited clients (free during beta; $99–199/month expected)
Learn more at home.fedix.ai and evaluate whether MyLedger fits your practice’s compliance operating model.
Frequently Asked Questions
Q: Is a director ID the same as an ACN, ABN or TFN?
No. A director ID identifies a person in their capacity as a director, while ACN identifies a company, ABN identifies an entity for business dealings, and TFN identifies a taxpayer. A director ID is permanent and stays with the person for life.Q: Can my accountant apply for my director ID?
No. ABRS requires the individual director to apply personally because identity verification is central to the regime. Your accountant can provide instructions and compliance support, but cannot complete the application on your behalf.Q: Do directors of corporate trustees need a director ID?
Yes, where the trustee is a company and the person is appointed as a director of that company. This is a common area where SME groups and family trusts inadvertently miss the requirement.Q: What happens if a director does not apply for a director ID?
Directors may be exposed to civil and criminal penalties under the Corporations Act 2001 and the director ID legislative regime. Accounting practices should document advice given and take remediation steps promptly.Q: Does a director ID ever change?
No. A director ID is intended to be held for life, even if the director changes companies, resigns, changes their name, or moves overseas.Disclaimer
This article is general information for Australian accounting and governance contexts as of December 2025. Tax and corporations law are complex and subject to change. It is advisable to consult the ABRS guidance and obtain legal or tax advice for entity-specific circumstances, particularly where director status is uncertain or disputes exist.