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. Not a PO box. The address where they live.
What changed
ASIC has been walking this back, first with a temporary patch and now with a permanent solution. On 11 September 2026 it released Consultation Paper 391: Access to information on the companies register. It sets out the future access settings for the register: what becomes public, what becomes restricted, and who can see what.
The consultation
Key dates
- February 2026PassedInterim fix. ASIC removed residential addresses from purchased company extracts as an interim measure while broader privacy arrangements were considered.
- 11 September to 12 October 2026NextConsultation open. Submissions on CP 391 close at 5:00pm on 12 October 2026.
- November 2026 to June 2027Build. ASIC designs, builds and tests the new registry services.
- March 2027Report on submissions. Released with a draft legislative instrument.
- Early 2027Final position. ASIC announces its final approach to access.
The full Consultation Paper is available on the ASIC website.
Why the change is happening
The current settings were developed when company information was less easy to search, download, combine and reuse. Access to a director’s address meant a paid company extract, delivered on paper or as a static file. Combining that information with anything else took manual work.
That world no longer exists. Company data is searched, downloaded and combined at scale. The same information that once supported transparency and market confidence now sits in easily accessible datasets. With cybercrime and impersonation scams rising, personal information on public registers has become both easier to misuse and more valuable to bad actors.
CP 391 states the tension directly. The register needs to remain useful for people who legitimately need to know who they are dealing with, including creditors doing due diligence, journalists investigating public-interest matters, and regulators enforcing the law. The settings developed for a slower information environment do not balance that transparency against 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 ASIC’s proposal for how those powers get used.
The service address, and why it matters
The centrepiece of the proposal is the introduction of service addresses. A service address is an alternative address where documents can be served on an officeholder. It replaces the residential address as the public-facing contact point.
What the proposal switches on
Key dates
- 1 July 2027 (proposed)NextLodgement opens. Director IDs, service addresses and electronic contact addresses. New registry services and access settings start.
- 1 July 2027 (proposed)Lodged documents are redacted. From this date, documents lodged with ASIC are provided in redacted form to general and business users, with restricted person details removed. Unredacted versions are only available through company or government access. This applies only to documents lodged from that date forward.
- 1 August 2028 (proposed)Full implementation. If a service address is lodged, the residential address stays off general public access. If a service address is not lodged, the residential address becomes publicly available on general access from this date.
What else CP 391 changes
The residential address change is the headline, but the proposal covers a wider shift in what becomes public and what does not.
Some information moves to free access. Officeholders’ names and status (current or ceased), which currently sit behind paid extracts, will become freely available. Director ID numbers will also move to free access. ASIC will introduce three new public flags: whether an individual director has confirmed their director ID, whether any or all directors of a company have confirmed theirs, and whether a company has an overdue annual review.
The flags are a subtle but material change. The confirmation status of a director ID and the currency of a company’s annual review will appear on the public-facing display, visible without needing to purchase a paid extract.
Some information becomes more restricted. Full date of birth will only be available to registered liquidators and government users. Year of birth will remain more broadly available. Place of birth will be restricted to registered liquidators and government users only. The name recorded on the director ID register and the electronic addresses of officeholders will be restricted to company and government access. General users and business users will not see either.
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 |
The categories map to the transparency-versus-privacy balance ASIC is trying to strike. 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
The proposal affects every firm advising a company client. The most immediate takeaway is a decision every director will need to make: lodge a service address with ASIC before 1 August 2028, or their home address becomes publicly searchable on the register from that date. That is the change every practitioner needs to walk their director clients through.
Officeholders who use their residential address as the registered office are the group most exposed under the current settings, and the group for whom a service address is most important.
What it means for your fees
A decision for every director client: lodge a service address, or accept that their home address becomes public from 1 August 2028. 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. Every company client with directors will need a decision on whether to lodge a service address. The choice is straightforward. A director who wants their home address off the register needs a service address. A director who does not mind their home address being public does not. The decision itself needs to be made, and firms are the natural point of contact for it.
Your firm’s dates
Key dates
- Now to 12 October 2026NextInformation sessions. ASIC is running information sessions during the consultation window, with expressions of interest handled through a survey link on the ASIC website. Firms wanting to attend can register through the same route.
- By 12 October 2026The submission. ASIC has raised twenty consultation questions in CP 391, grouped under four themes: information types and access settings, display flags, user groups and verification, and impacts and costs. Firms with views on any of them can submit by 5:00pm to consultation.registrydata@asic.gov.au. The paper invites feedback on alternative approaches as well as on the specific questions. Feedback is not treated as confidential unless specifically requested.
- Before March 2027Start the conversations. Starting before the March 2027 report gives firms time to work through their client base methodically. Starting them after ASIC announces its final position risks a rush against the 1 August 2028 deadline.
- 1 July 2027 to 1 August 2028Lodge. Lodgement of service addresses opens on 1 July 2027. That gives every director in Australia one year and one month to make a decision and act on it. For firms managing hundreds of company clients, that timeline is tight.
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.
What would change the advice
Key dates
- March 2027NextReport on submissions. ASIC says it will release a report and a draft legislative instrument.
- Early 2027The final position. The assumption most likely to be wrong is the default. The advice to start client conversations now assumes the final model still makes a residential address public when no service address is lodged. If submissions move ASIC to keep residential addresses off general access either way, the client project shrinks to a courtesy note.
- 1 July 2027 (proposed)Lodgement mechanics. What we have not been able to verify: how lodgement will work in practice, including whether a firm acting as a company agent can lodge a service address on a director’s behalf, and what the business access fee will be. We have not seen either published.
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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