The Eleven Registers Every Supplier Should Be Checked Against

There is no single authoritative register for business legitimacy in Australia. Legitimacy is distributed across eleven separate government databases, each operated by a different agency, each catching something the others do not. A business can look clean in ten of them and be a serious risk in the eleventh.

This is a checklist. Use it to understand what each register covers, what it misses, and why the combination matters more than any individual check. Each register is publicly available; each adds a dimension that the others do not capture.

Register 1: The Australian Business Register (ABR)

What it covers: ABN status, entity type, GST registration, main business location, and trading names. The ABR is the foundational register — every Australian business with an ABN is in it.

What it catches: Cancelled or lapsed ABNs; entities claiming GST registration they do not have; mismatches between the registered address and the business location given to you.

What it misses: Everything else. An ABN being active says nothing about the entity's financial health, compliance history, or legitimacy as a trading counterparty. It only tells you the entity exists in the system.

Where to check: abn.business.gov.au

---

Register 2: ASIC Company Register (3.4M companies)

What it covers: All registered companies in Australia, their registration status, ACN, principal place of business, and officeholders.

What it catches: Deregistered companies still being used as counterparties (extremely common in fraud). Companies under external administration — though with a lag (see Register 4). Addresses that do not match what the supplier has told you.

What it misses: Sole traders, partnerships, and trusts — these are not registered with ASIC. A company that registered yesterday and incorporated a new entity to escape a failed predecessor.

Where to check: connectonline.asic.gov.au

---

Register 3: ASIC Business Names Register (2.9M names)

What it covers: All registered business (trading) names. A business name is the public-facing name a company or individual trades under when it differs from their registered company name or individual name.

What it catches: Cancelled or lapsed business names still being used on invoices; a supplier trading under a name that is registered to a different entity; names that are deregistered but still appearing on active websites and marketing.

What it misses: Unregistered trading names (many legitimate businesses trade under informal names without registering them). Does not confirm the entity behind the name is legitimate.

Where to check: connectonline.asic.gov.au — business names search

---

Register 4: ASIC External Administration (Insolvency Gazette)

What it covers: Companies currently under external administration — voluntary administration, receivership, liquidation, or court-ordered winding-up.

What it catches: Suppliers in active insolvency proceedings — though the ASIC bulk data lags gazette notices by weeks. The Insolvency Notices Gazette (published weekly) catches these earlier. Companies in voluntary administration may still be trading; those in liquidation are not.

What it misses: The lead time. A supplier that entered administration on Monday may not appear in bulk ASIC data until the following month. Check the gazette directly for current status.

Where to check: ASIC Connect (bulk data); insolvencynotices.com.au (gazette, real-time)

---

Register 5: ASIC Banned and Disqualified Persons (7,100+ records)

What it covers: Individuals banned from managing corporations, banned from providing financial services, disqualified from acting as liquidators, or subject to other ASIC prohibitions.

What it catches: A director of a supplier who is legally prohibited from managing a company — either because of a prior insolvency event, a criminal conviction, or a civil penalty order. This is the Phoenix pattern made visible: a banned director who has re-emerged in a new entity.

What it misses: Directors who should be banned but have not yet been the subject of ASIC proceedings. International bans (Australian bans do not cover foreign-jurisdiction conduct). Directors acting through nominees.

Where to check: moneysmart.gov.au/banned (ASIC's financial service ban register)

---

Register 6: ATO Super Fund Lookup

What it covers: APRA-regulated superannuation funds and licensed trustees. Relevant when your supplier is a financial services entity or when you are verifying a fund to which you make contributions.

What it catches: Non-complying funds, deregistered funds, and fraudulent "super fund" entities that are not registered with the ATO.

What it misses: Most suppliers — this register is only relevant for financial services entities and super funds.

Where to check: superfundlookup.gov.au

---

Register 7: ATO Superannuation Guarantee Non-Compliance

What it covers: Employers who have failed to meet Superannuation Guarantee obligations. The ATO pursues SG non-compliance vigorously — but it does not publish a named-employer register in bulk-accessible form. The ATO names employers through proceedings, court outcomes, and media releases, but there is no structured register available for programmatic verification or public download.

What it catches: SG liability indicators are sometimes visible indirectly — through Fair Work enforcement actions (the FWO does publish outcomes), adverse records from ASIC proceedings, or commercial data aggregators who compile ATO enforcement media. Construction and labour-hire buyers with shared SG liability exposure should use Fair Work outcomes as the primary signal.

What it misses: This is the gap. Employers with active SG non-compliance who have not been the subject of ATO proceedings or media-named enforcement are not discoverable through any public register. The absence of a record is not confirmation of compliance.

Where to check: No direct public register is available. Use Fair Work Ombudsman outcomes (Register 9) as the primary compliance signal. The ATO names employers in enforcement proceedings on its website but does not maintain a structured lookup register.

---

Register 8: ATO Tax Debt Disclosure

What it covers: Businesses with more than $100,000 in collectable tax debt that the ATO has disclosed to credit reporting bureaus under the Treasury Laws Amendment (2019) Act.

What it catches: Businesses in significant financial distress that have not entered a payment arrangement with the ATO — a leading indicator of cash-flow problems. Banks and credit bureaus already see this; your AP team probably does not.

What it misses: Debts under $100K. Businesses in active payment arrangements (removed from list). Does not cover GST debts separately from income tax.

Where to check: Credit bureau products (CreditorWatch, Equifax, Experian, D&B) — the ATO discloses to credit bureaus, not a public download register.

---

Register 9: Fair Work Ombudsman Compliance Register

What it covers: Enforceable undertakings, compliance notices, and infringement notices issued by the Fair Work Ombudsman for workplace law violations.

What it catches: Suppliers who have been formally found to have underpaid workers — relevant for labour-hire, hospitality, construction, and any industry where shared employer liability applies under the Fair Work Act.

What it misses: Investigations that are ongoing or resolved informally. Matters settled without formal enforcement action.

Where to check: fairwork.gov.au — compliance and enforcement outcomes

---

Register 10: ASIC Financial Services and Credit Register

What it covers: All current and former holders of Australian Financial Services Licences, Australian Credit Licences, and registration as a registered managed investment scheme.

What it catches: Financial services suppliers claiming an AFS licence they do not hold; licences that have been revoked, suspended, or cancelled; unlicensed financial services activity.

What it misses: Authorised representatives (ARs) who act under someone else's licence — these require a separate check. International financial services entities operating in Australia under ASIC class orders.

Where to check: ASIC Connect — professional registers

---

Register 11: State Trade Licences (QBCC, NSW Fair Trading, VIC CBS, Others)

What it covers: Trade licences for building, construction, electrical, plumbing, and related work — issued by state and territory licensing authorities. Each state has its own register; there is no national consolidated source.

What it catches: Building contractors and tradespeople operating without a valid licence; licences that have been suspended or cancelled for disciplinary reasons; contractors operating in a state where they are not licensed.

What it misses: Interstate licence portability is not automatic — a contractor licensed in Queensland may not be licensed in New South Wales for the same work. Check the specific state register for the state where work will be performed.

Where to check: QBCC (qld.gov.au/housing), NSW Fair Trading (fairtrading.nsw.gov.au), VIC Consumer Affairs (consumer.vic.gov.au)

---

Using the Checklist in Practice

Manual checking across all eleven registers takes 30–45 minutes per supplier and requires knowing which registers apply to which supplier type. The practical approach is to segment your supplier base and check the relevant registers for each segment:

• All suppliers: ABR, ASIC Company Register, ASIC External Administration
• All new suppliers: Add ASIC Banned & Disqualified, ATO Tax Debt, ASIC Business Names
• Suppliers providing labour or services to your premises: Add FWO Compliance (Register 9)
• Trades and construction: Add State Trade Licences (relevant state only)
• Financial services entities: Add ASIC Financial Services Register, ATO Super Fund Lookup

Most of these registers are public. The data exists. The bottleneck is time and process. Gumshoe checks the publicly accessible registers in a single verification run, surfacing results in a structured report with a timestamp and data source citation for each. For any supplier relationship worth more than your team's time to manually reconstruct an audit trail, it is the efficient path.

Keep this checklist. Use it during onboarding reviews, contract renewals, and any time a new supplier contact says "just check the ABN." An active ABN is the start of due diligence, not the end of it.

Uncommon Insights

Uncommon Insight: A supplier with an active ABN and ASIC registration can still be a significant risk if they are under external administration, which may not be immediately apparent on the ASIC Company Register. The ASIC External Administration (Insolvency Gazette) register, while not as well-known, is crucial in identifying companies under external administration, and it's essential to check this register in conjunction with the ASIC Company Register to get a complete picture. This is particularly relevant under section 600K of the Corporations Act 2001 (Cth), which deals with the consequences of a company being under external administration.

Another Uncommon Insight: The ATO's Departed Employee Superannuation Guarantee (DESG) register, while not typically considered in supplier legitimacy checks, can reveal a supplier's history of non-compliance with employee superannuation obligations. This register can be used to identify suppliers who have failed to pay employee superannuation, which may indicate broader financial or compliance issues. CFOs and accountants should be aware of this register, as it can provide valuable insights into a supplier's financial health and compliance history.

A further Uncommon Insight: ASIC's Banned and Disqualified Persons register can help identify suppliers who have had individuals banned or disqualified from managing companies due to past misconduct. However, this register is often overlooked in supplier legitimacy checks. CFOs and accountants should check this register to ensure that the supplier's management team does not include individuals with a history of corporate misconduct, which could pose a risk to their business. This is particularly relevant under section 206F of the Corporations Act 2001 (Cth), which deals with the disqualification of persons from managing companies.

Lastly, an Uncommon Insight: The Australian Securities and Investments Commission (ASIC) has a pattern of enforcement that focuses on companies that have failed to comply with their obligations under the Corporations Act 2001 (Cth). CFOs and accountants should be aware of ASIC's enforcement priorities and check the ASIC Register of Enforceable Undertakings to identify suppliers who have entered into enforceable undertakings with ASIC. This can provide valuable insights into a supplier's compliance history and potential risks associated with doing business with them.