“At present, we understand that once a director ID has successfully been issued, there is currently no option to nominate an authorised agent within the directors’ profile,” CA ANZ said in the submission.

“In the development of subsequent data standards, we suggest careful consideration is given to the process by which a director can nominate an authorised agent, the information an agent is able to update (such as address, postal address, phone numbers) as well as the tracking of information changed by the agent.”

In particular, CA ANZ noted that currently, there remains a lack of transparency for directors applying for a director ID as to how their director ID information will be linked to relevant companies and which aspects of this information will ultimately be publicly displayed through the ABRS.

“We encourage the ATO to provide such clarity on issuing a director ID and throughout each stage of the MBR project through frequent and detailed communication with director ID holders,” CA ANZ noted.

In the submission, CA ANZ also recommended establishing a regular communication channel between the registrar and directors to convey alerts and information relating to MBR and director ID, for example how directors should treat their number and who they can share it with. 

“Continuing to support directors, their advisers and authorised agents during this transitional phase of the director ID program will be important,” CA ANZ explained.

“For example, further clarification in areas such as the difference between MyGov and MyGovID, the practical requirements for foreign directors and the different registration deadlines will help to provide transparency and direction for directors and stakeholders.

“Any of our members are also directors and have indicated that they are unsure about ‘the next steps’ after receiving their director ID. There has been limited communication about how directors should treat their number and who they can share it with. 

“For example, is it a sensitive number like a tax file number (TFN)? What is the timeline for next steps? What information will be publicly disclosed? We recommend establishing a regular communication channel between the registrar and directors to convey alerts and information relating to MBR and director ID. This would also be beneficial for advisers, authorised agents and intermediaries to stay informed of developments.”

The director ID information that currently appears on the ABRS (Australian Business Registry Services) website provides a range of useful information. However, this requires the users to visit and navigate the website, according to CA ANZ.

“We suggest consideration is given to concise downloadable documents, which can be digitally shared by authorised agents and intermediaries as well as professional bodies such as ourselves,” CA ANZ continued.

“For example, these could include an illustrative flowchart to outline the pathways to apply for a director ID (online, phone, paper) or the pathways for new and existing directors to follow for application.

“Currently the Attorney-General’s [Department] (the Department) is consulting on the Privacy Act Review (due January 2022). We suggest the ATO closely monitors and collaborates with the Department in relation to this review to identify potential alignments and/or conflicts with the MBR and director ID.”