ATO’s administration of Director Penalty Notices
Submission Date: 9 October 2026
The Business Law Section of the Law Council of Australia (the BLS) welcomes the opportunity to participate in the Ombudsman’s review (Review) of the Australian Taxation Office’s administration of the Director Penalty Notices (DPN) regime.
This submission is made with the joint input of the Taxation Committee, the Insolvency & Restructuring Committee, and the Small and Medium Enterprise Business Committee (together, the Committees) of the BLS.
This submission identifies a number of themes experienced by practitioners who are members of the Committees. While anonymised anecdotes can at times be unhelpful in isolation, the consistent and broad experience reported by practitioners consulted for this Review is that there are serious issues with the administration of the DPN regime.
Last Updated on 12/10/2026
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