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Lender Briefing - ATO Enforcement - October 2026

Two ATO notices. Two different problems for your borrower.

For credit, workout and portfolio teams

A Director Penalty Notice and a Direction to Pay are routinely confused, can arrive in close succession, and each changes how a board behaves over the following 21 days. This briefing sets out how the two notices differ and what they tell a lender about the borrower.

Rebound AdvisoryOctober 20264 pagesDownload PDF

Authors: Brendan Richards and Claire GaffneyPublished 27 October 2026

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Cover of the Rebound Advisory Lender Briefing on ATO enforcement, October 2026

At a glance

21 days

Both notices run on a 21 day clock

84,000+

Director Penalty Notices issued to directors in FY2024-25.

$1.73bn

super guarantee charge raised by the ATO in 2024-25

In this briefing

01The two notices side by side

02What the notices tell you about the borrower

03Six questions worth asking this week

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Download the briefing (PDF)