That surge in DPN use is now drawing regulatory scrutiny of its own. The tax ombudsman’s review of how the ATO administers DPNs is scheduled to begin this month, examining cases including directors who were unaware of their personal liability or affected by illness. The review notes that the ATO issued more than 84,000 DPNs to directors of approximately 64,000 companies in the 2024–25 financial year, a 136% increase on the prior year.

