Companies · Trusts · SMSFs — identity checks explained
The identity checks when you set up a company, trust or SMSF
Whatever structure you’re setting up, the people behind it now go through an identity check before we can finalise it — partly a government requirement, and partly a check we’re required to carry out. This page explains what you’ll need, who gets verified for each structure, and why.
Two identity steps, not one
It’s easy to assume identity checks come from the government registering your structure. For companies, ASIC doesn’t actually verify your identity to register the company — and a trust deed isn’t registered with ASIC at all. The identity requirements come from two separate places, and they’re worth keeping apart.
| Director ID | KYC / identity check | |
|---|---|---|
| What it is | A unique number that permanently identifies a company director. | Confirming who you are against your ID before we provide the service. |
| Who requires it | The government, through Australian Business Registry Services (ABRS). | The AML/CTF Act, overseen by AUSTRAC. |
| Who does it | You — each director applies personally. It can’t be done by an agent. | We do — we verify you as part of your order. |
| When it applies | Whenever a company is in the structure — including a company acting as trustee. | Every structure — companies, trusts and SMSFs. |
| Cost | Free. | Included in our service. |
The rest of this page is about the second column — the KYC check we carry out. For the Director ID, each director applies directly through the ABRS; we’ll simply ask you to record the number on your order.
What KYC actually means
Know Your Customer (KYC) is just what it sounds like — knowing who we’re dealing with. The formal version is customer due diligence: a short set of checks that confirm who you are and who’s really behind the structure being set up.
In practice it comes down to three things at the start of your order:
- Identify each person involved — name, date of birth, address.
- Verify those details against real evidence, like a passport or driver licence.
- Understand who’s in control — work out who ultimately owns or controls the structure, not just whose name is on the form.
For a straightforward structure with one or two Australian individuals, it’s a quick step.
Why we have to verify you
Australia’s anti-money-laundering law — the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, overseen by AUSTRAC — used to apply mainly to banks and similar businesses. From 1 July 2026, reforms known as “Tranche 2” extend it to the professionals who set up companies, trusts and SMSFs. We’re now a reporting entity, which means we must verify our clients before we finalise your documents.
Companies are still quick, and deeds are still reviewed and delivered on the usual timeframe. The difference is that the ID check happens first — we can’t finalise until it’s done. The single best thing you can do to keep your order fast is to have everyone’s ID ready when you order.
Allan’s Off The Shelf is putting in place the systems and documented identity-verification procedures required for these checks ahead of the 1 July 2026 commencement date.
Who we verify — by structure
The checks are the same; the people we verify depend on what you’re setting up. Here’s who is generally in scope for each.
Company
- Each director
- Each shareholder
- Beneficial owners (25%+ or control)
- Director ID for every director
Trust
- The trustee(s)
- The appointor / guardian (who can hire and fire the trustee)
- The settlor
- Beneficiaries, or classes of beneficiary
- If the trustee is a company: that company and its directors
SMSF
- Each member of the fund
- The trustees (individual trustees, or the directors of a corporate trustee)
- If there’s a corporate trustee: that company and its directors
- Director ID for each corporate-trustee director
If you’re ordering a combined package — for example a company and a trust, or an SMSF with a corporate trustee — we verify the people across the whole structure, not each part separately.
What you’ll need — each person
For each person in scope (see section 04), we collect and confirm a few basic details.
| We need | Detail |
|---|---|
| Full legal name | Exactly as it appears on your photo ID. |
| Date of birth | Confirms your identity and avoids mix-ups between similar names. |
| Residential address | A current home address — not a PO Box on its own. |
| Photo ID | A current Australian driver licence or passport is the usual choice. Overseas individuals can use a current foreign passport. |
| Director ID (directors only) | The number each company director gets from the ABRS — see section 01. |
Separately from identity, any company in your structure (including a corporate trustee) must have at least one director who ordinarily lives in Australia. If your proposed directors are all overseas, you’ll need to add a local director. Ask us if you’re not sure.
Please don’t email copies of your ID before we request them. We’ll tell you which documents we need and the secure way to send them, so your personal details aren’t sitting in an inbox.
What you’ll need — when a company is involved
Sometimes a part of the structure is itself a company — a corporate shareholder, a holding company, or a corporate trustee of a trust or SMSF. When that happens, we verify both the company and the real people behind it.
| We need | Detail |
|---|---|
| Company name & number | Full registered name and ACN (and ABN if it has one). |
| Registered office | The company’s registered address in Australia. |
| Directors | Verified as individuals, the same way as section 05. |
| Owners & controllers | The people who ultimately own or control that company — its beneficial owners. |
A company is never the end of the trail. Behind every corporate trustee or corporate shareholder are real people, and we’re required to identify them.
Beneficial ownership: who’s really behind it
A beneficial owner is the real person who ultimately owns or controls a structure — as opposed to whoever simply appears on the paperwork.
For companies
As a general guide, it’s someone who ultimately owns or controls 25% or more of the shares or votes, or who controls the company in another way.
When shares are held “on trust”
This is the part people most often get backwards. If shares are held on trust for someone else, the legal holder isn’t the whole answer — we need the details of the person the shares are actually held for. That person is the beneficial owner. So whenever a holding is “held on trust”, expect us to ask: held on trust for whom?
For trusts and SMSFs
“Who controls it” reaches wider than the trustee. Depending on the structure it can include the trustee(s), the appointor or guardian, the settlor, and the beneficiaries or classes who benefit from or control the trust. We’ll identify the relevant people for your particular deed.
How we verify your identity
Collecting details is only half of it — we also confirm they’re genuine. Depending on your order, that may be an electronic check or a certified copy of a document.
A certified copy is simply a photocopy that a qualified person — such as a Justice of the Peace, lawyer, accountant or pharmacist — has signed to confirm it’s a true copy of the original. It’s an everyday process, not a formal legal ceremony.
- Documents that aren’t in English may need a certified English translation.
- Some overseas documents may need extra certification to be accepted.
- We’ll always tell you exactly what’s needed in advance — nothing is a surprise.
Records, retention & your privacy
The law requires us to keep these identity records for seven years. We treat them as confidential and handle them under the Privacy Act 1988 and the Australian Privacy Principles.
- We collect this only to meet our legal obligations and to provide the service you’ve ordered.
- It’s stored securely, and access is limited to those who need it.
- We don’t sell it, and we don’t use it for marketing without your consent.
Making your order smooth
The whole check is quick if you come prepared. Before you order:
- Have photo ID ready for every person involved in the structure.
- Get a Director ID from the ABRS for each director of any company — including a corporate trustee — if they don’t already have one.
- Know who controls what — especially appointors and settlors for trusts, and anything held on trust.
- Check residency — make sure any company has at least one director who ordinarily lives in Australia.
If you’re an accountant or lawyer ordering on a client’s behalf, we’ll confirm exactly whose identity needs verifying for your structure. Get in touch before you order and we’ll walk you through it.
Frequently asked questions
Does the government check my ID when I set up a company or trust?
Not as a KYC check. ASIC registers a company but doesn’t verify your identity to do so, and a trust deed isn’t registered with ASIC at all. The identity requirements come from two other places: a Director ID for company directors (from the ABRS), and the KYC check we carry out under anti-money-laundering law.
Do trusts and SMSFs need this too, or just companies?
All of them. The rules apply to the people who set up companies, trusts and SMSFs from 1 July 2026. Who gets verified differs by structure — see “Who we verify” above — but every structure is covered.
What’s a Director ID and when is it needed?
It’s a unique number that permanently identifies a company director. It’s free, you apply for it yourself through the ABRS, and it’s needed for every director of any company in your structure — including a company acting as trustee. An agent can’t obtain it for you.
Will the ID check slow my order down?
Companies are still quick and deeds are delivered on the usual timeframe. The ID check just happens first. Having everyone’s documents ready when you order is what keeps the whole thing fast.
How long do you keep my details, and are they safe?
We’re required to keep identity records for seven years. They’re stored securely, access is restricted, and they’re handled under the Privacy Act 1988 and the Australian Privacy Principles.
Important information
This page is general information about the identity checks involved in setting up a company, trust or SMSF, and is not legal, tax or financial advice. Requirements depend on your circumstances and can change. You should seek advice tailored to your situation before acting.
Information current as at 29 June 2026.