Australia’s defence supply chain is vetted carefully at the door. After that, most of what is known about a supplier’s owners, directors and financial health comes from the supplier itself, once a year. Distintel watches the public record continuously and tells you when it stops matching what was declared.
There is no single approved-supplier register. A new supplier passes a series of separate gates, run by different parts of government. The security gate, the Defence Industry Security Program (DISP), decides whether the supplier can work with classified information.
| Gate | What is checked | Evidence |
|---|---|---|
| EligibilityCommonwealth Procurement Rules | An ABN or ACN, and each tender’s own conditions for participation. | Declared |
| Tax recordShadow Economy PCP | For procurements of $4m+ (incl. GST), a valid and satisfactory ATO Statement of Tax Record, also held for known first-tier subcontractors. | ATO issued |
| ConductSupplier Code of Conduct | A process for declaring and managing conflicts of interest. In every Commonwealth contract since 1 July 2024. | Declared |
| Financial viabilityDefence commercial & financial analysis | Three years of audited financial statements, plus any foreign person or body able to exercise or influence control. | Supplier supplied |
| Security membershipDISP · DSPF Control 16.1 | Australian entity, financially solvent, a Chief Security Officer and Security Officer, a director able to hold a clearance, and ASD Essential Eight at Maturity Level 2 (mandatory from 15 Nov 2025). Four levels, from Entry to Level 3 (TOP SECRET). | DeclaredAssessed |
| Foreign ownership, control or influenceDISP FOCI · PSPF Direction 001-2024 | Whether a foreign interest has “direct or indirect power, whether or not exercised” over management or operations. For technology purchases, agencies ask about non-Australian directors, foreign shareholders and foreign revenue. | DeclaredAssessed |
| Export controlsDefence Trade Controls Act | Permits for controlled goods and technology. Since 2024, supplying controlled technology to a foreign person is an offence in its own right. | Where applicable |
| Obligation | What happens | Who reports |
|---|---|---|
| Annual Security Report | Due each year around the DISP membership anniversary. Attests to Essential Eight ML2, current clearances for security officers, reportable incidents and FOCI changes. | Supplier |
| Security officer changes | A new Chief Security Officer or Security Officer must be notified to Defence. | Supplier |
| Ownership or control changes | Must be notified, and trigger a fresh FOCI assessment. | Supplier |
| Foreign acquisitions | A foreign investor taking 10%+ of a national security business, or less with influence, must notify FIRB and get approval, whatever the deal size. | Acquirer |
| Assurance and audit | Defence reviews members, runs a Return to Compliance program, and can escalate to suspension or termination of membership. | Defence |
| Personnel clearances | Revalidated periodically. Holders report changes in their own circumstances. | Individual |
Nearly every ongoing control above depends on the supplier noticing a change, recognising that it matters, and choosing to report it. Between annual reports nothing independent checks the public registers. A new foreign director, a change of parent company, or a winding-up application against a holding company can sit unreported for up to a year.
Distintel does not replace DISP or the FOCI assessment. Those draw on classified and declared information we will never hold. We give your procurement team a second, independent view of the same supplier, and alert you when the two disagree.
| Your question | What Distintel provides | Status |
|---|---|---|
| Is the supplier healthy? | Company and ABN status, ASIC insolvency and deregistration notices, winding-up applications against the supplier or its group, credit-register changes. | Live |
| Who runs it? | Directors, secretaries and related parties, with every other company each person is linked to. | Per supplier |
| Who ultimately owns it? | Ownership walked through companies and trusts to beneficial owners on AUSTRAC’s three-tier test, drawn as a structure chart. Where the chain leaves Australia, we mark the point it does. | Per supplier |
| Who else is it tied to? | Group discovery from one ABN: holding companies, trustees, sister entities and joint ventures, with shared directors across them. | Live |
| Has something changed? | A watchlist over your supplier panel, with alerts on status, officeholder, ownership and notice events. | Live |
| Is there outside influence? | Screening against the DFAT consolidated sanctions list, and flags for newly appointed directors or shareholders resident overseas. | In build |
“Per supplier” items are built from ASIC company extracts ordered for each supplier and then kept current. Rows marked “In build” are not yet generally available.
ASIC now records the holding company as an entity registered outside Australia.
One new director. Two long-standing directors resigned in the same week.
Filed against a sister company that shares two former directors with the supplier.
Names and events above are invented to show the format. None of them describe a real company.
A list of ABNs or ACNs, starting with the suppliers you consider highest risk or most sensitive.
For each supplier: status, officeholders, group structure and ownership chain, as the public record shows them today.
Your team checks the baseline against each supplier’s own FOCI and ownership declarations. Differences found at this stage are often the most useful result of the pilot.
The panel goes on a watchlist, and changes are sent to the procurement or security officer responsible for each supplier.
We’ll reply within one business day to set up a scoping call.