Your director clients need a service address by 1 August 2028
ASIC’s proposed companies register settings would make a director’s residential address public from 1 August 2028 unless a service address has been lodged. Firms should start the client conversation now and consider a submission before 12 October 2026.
18 September 2026 · 9 min read
For years, every company director in Australia has had their residential address sitting on a public register. Buy an ASIC company extract, and the home addresses of every director appear on it: not the office or a PO box, but the address where they live.
What changed
On 11 September 2026 ASIC released Consultation Paper 391: Access to information on the companies register, the permanent fix after a temporary patch. It sets out what becomes public, what becomes restricted, and who can see what.
ASIC’s dates
Key dates
- February 2026PassedInterim fix. ASIC removed residential addresses from purchased company extracts while broader privacy arrangements were considered.
- 11 September to 12 October 2026NowConsultation open. Submissions on CP 391 close at 5:00pm on 12 October 2026.
- November 2026 to June 2027NextBuild. ASIC designs, builds and tests the new registry services.
- Early 2027Final position. ASIC announces its final approach to access.
- March 2027Report on submissions. Released with a draft legislative instrument.
- 1 July 2027 (proposed)Lodgement opens for director IDs, service addresses and electronic contact addresses, and the new registry services and access settings start. Documents lodged from then reach general and business users with restricted person details removed; unredacted versions need company or government access.
- 1 August 2028 (proposed)Full implementation. With a service address lodged, the residential address stays off general public access. Without one, it becomes publicly available on general access from this date.
Why the change is happening
The current settings date from when a director’s address meant a paid company extract, on paper or as a static file, and combining it with anything else took manual work. Company data is now searched, downloaded and combined at scale, and with cybercrime and impersonation scams rising, personal information on public registers is easier to misuse and more valuable to bad actors.
CP 391 states the tension directly. The register must stay useful to people who legitimately need to know who they are dealing with, such as creditors doing due diligence, journalists investigating public-interest matters and regulators enforcing the law, while weighing the privacy and safety risks a searchable register creates today. The Treasury Laws Amendment (Business Registries Stabilisation and Uplift) Act 2026 gave ASIC the powers to fix this; CP 391 is its proposal for how to use them.
The service address, and why it matters
The centrepiece of the proposal is the service address: an alternative address where documents can be served on an officeholder. It replaces the residential address as the public-facing contact point.
What else CP 391 changes
The residential address is the headline, but the proposal shifts more than that.
Moving to free access
- Officeholders’ names and status (current or ceased), which now sit behind paid extracts.
- Director ID numbers.
- Three new public flags: whether an individual director has confirmed their director ID, whether any or all of a company’s directors have confirmed theirs, and whether a company has an overdue annual review. They show on the public display without a paid extract.
Becoming more restricted
- Full date of birth and place of birth: registered liquidators and government users only. Year of birth stays more broadly available.
- The name on the director ID register and officeholders’ electronic addresses: company and government access only.
The four user categories
CP 391 proposes four categories of access. The category determines what a user can see.
| Access | Who | Fee |
|---|---|---|
| General | The default. Anyone can access general information via free or paid extracts, without needing to verify who they are or what they need the information for. | Free or paid extracts |
| Company | The company itself and the people connected to it: its officeholders, other officers such as auditors, appointed liquidators and registered external administrators, and authorised representatives such as company agents, legal representatives and community advocates. | None |
| Business | A new category for three verified professional user types. Registered liquidators, for pre-engagement checks and investigative functions. Legal practitioners, to support litigation and serve legal documents. Journalists and media organisations, for public-interest investigative reporting. | Yes, except journalists and media, who are eligible for a fee exemption |
| Government | Regulatory, law enforcement and other government bodies, for official purposes. | Yes, unless an exemption is available |
General access sees enough to identify a company and its officeholders. Business access sees more, but only for verified professional need. Company and government access see everything.
What it means for your firm
Every director client faces one decision: lodge a service address before 1 August 2028, or their home address becomes publicly searchable from that date. Directors who use their residential address as the registered office are the most exposed.
What it means for your fees
Across a client base, gathering service addresses, updating ASIC records and confirming lodgement is a project, not a task.
Start from a list of director clients and flag the ones who use their residential address as the registered office, because they are the most exposed. Keep the advice conversation separate from the lodgement work. If a client asks to use your office instead, read what using your office for ASIC correspondence costs you first, and note that providing a registered office address is a designated service under the AML/CTF regime.
Price it as a defined project with its own line in the engagement, not as a favour inside the annual fee. Count the directors, time a small first batch, and set the fee from that and your own costs. Lodgement is proposed to open on 1 July 2027, so there is time to measure before you quote.
ASIC has proposed that from 1 August 2028 a director’s home address will be publicly searchable unless a service address has been lodged, with lodgement expected to open on 1 July 2027. We will contact you before then to confirm what you would like to do.
What to do this week
The client conversation. A director who wants their home address off the register needs a service address; one who does not mind it being public does not. Either way the decision has to be made, and the firm is the natural point of contact for it.
Your firm’s dates
Key dates
- Now to 12 October 2026NowInformation sessions. ASIC is running sessions during the consultation window; register through the survey link on the ASIC website.
- By 12 October 2026NextThe submission. CP 391 asks twenty questions under four themes (information types and access settings, display flags, user groups and verification, and impacts and costs) and invites alternative approaches. Submit by 5:00pm to consultation.registrydata@asic.gov.au. Feedback is not treated as confidential unless you ask.
- Before March 2027Start the conversations. Starting before the March 2027 report lets you work through the client base methodically; waiting for the final position risks a rush against the 1 August 2028 deadline.
- 1 July 2027 to 1 August 2028Lodge. Every director in Australia gets one year and one month to decide and act, which is tight for a firm with hundreds of company clients.
Where we could be wrong
CP 391 is a consultation paper, not a final rule. Everything here about 1 July 2027 and 1 August 2028 rests on ASIC’s proposed model. Our 2026-27 compliance calendar tracks the dates and will change if ASIC’s do.
The final position, early 2027. The advice to start now assumes the final model still makes a residential address public when no service address is lodged. That default is the assumption most likely to be wrong: if submissions move ASIC to keep residential addresses off general access either way, the client project shrinks to a courtesy note.
Lodgement mechanics. We have not seen published how lodgement will work, including whether a firm acting as a company agent can lodge a service address on a director’s behalf, or what the business access fee will be.
Frequently asked questions
What if a director does nothing?
Under the proposal, their home address becomes public on 1 August 2028. Until then nothing changes.
When can a director lodge one?
From 1 July 2027 under the proposal. Confirm it once the final position is out.
Does it have to be our office?
No. Any address where documents can be served will do.
Who will see a full date of birth?
Only registered liquidators and government users, under the proposal.
Can our firm make a submission?
Yes, by 5:00pm on 12 October 2026. Feedback is public unless you ask for confidentiality.
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