The Director Identification Number

Section 155: one number only. No individual who has already been allotted a DIN shall apply for, obtain or possess another. The three verbs matter: possession alone offends, so a person who acquired a second number without applying afresh must surrender it.

Section 156: the individual tells the companies. Every existing director shall, within one month of receiving his DIN from the Central Government, intimate it to the company or all companies in which he is a director.

Section 157: the company tells the Registrar. Every company shall, within fifteen days of receiving that intimation, furnish the DIN of all its directors to the Registrar or such other officer or authority as the Central Government specifies, with the prescribed fees or additional fees, in the prescribed form and manner. Section 157(2) penalises the company and every officer in default for failure.

Section 158: the number is quoted everywhere. Every person or company, when furnishing any return, information or particulars required under the Act, shall mention the DIN where the return or information relates to a director or contains any reference to a director.

Section 159: the penalty. If any individual or director makes default in complying with section 152, section 155 or section 156, he is liable to a penalty which may extend to fifty thousand rupees, and, where the default is continuing, a further penalty up to five hundred rupees for each day after the first.

Note who is penalised where. Section 159 reaches the individual for his own defaults; s.157(2) reaches the company and its officers for the filing default. Getting that division right is worth a mark, because it reflects the design: each link answers for its own failure.

A worked example

Mr. Kulkarni is invited to join the board of Konkan Marine Limited in April 2026. He was allotted a DIN in 2019 when he became a director of two other companies, and had forgotten it, so he applies afresh and is allotted a second number in May 2026.

The appointment. He cannot be appointed until he has a DIN: s.152(3) forbids appointment unless a DIN has been allotted under s.154, or such other number as is prescribed under s.153's proviso. Having one from 2019, he was always eligible.

The second number. Applying for and now possessing it breaches s.155 in all three of its verbs. Under s.159 he is liable to a penalty up to fifty thousand rupees, with a further penalty up to five hundred rupees a day while the default continues, and the practical step is to surrender the later number in the prescribed manner.

The intimations. On receiving a DIN he must, within one month, intimate it to all the companies in which he is a director, s.156, not merely to the new one. Each of those companies must then, within fifteen days of the intimation, furnish it to the Registrar, s.157(1), failing which the company and its officers in default are penalised under s.157(2).

And thereafter. Every return or filing by him or by any of his companies that relates to or refers to a director must quote the DIN, s.158. That is how the register links him across all four companies, which is precisely what makes the disqualification and directorship-limit provisions enforceable.

One variation. Suppose Mr. Kulkarni had never held a DIN and the company appointed him anyway, taking his consent and filing it under s.152(5). The appointment offends s.152(3), the individual is exposed under s.159, and the company's filings would be defective for want of the number s.158 requires.

Distinctions

What it does NOT mean

Not a qualification. A DIN says nothing about a person's fitness; disqualification is governed by s.164 and vacation by s.167.

Not per company. One number covers every directorship the individual holds, which is the point of s.155's prohibition.

Not always a DIN. Section 153's proviso lets the Central Government prescribe another identification number to be treated as a DIN, which s.152(3) recognises.

Quick revision

s.153: application to the Central Government by every individual intending to be a director; proviso allows a prescribed identification number to be treated as a DIN. s.154: allotment within one month. s.155: no individual may apply for, obtain or possess a second DIN. s.156: director intimates his DIN to all his companies within one month of receipt. s.157: company furnishes DINs of all directors to the Registrar within fifteen days of intimation; s.157(2) penalises default by the company and officers. s.158: DIN quoted in every return, information or particulars relating to or referring to a director. s.159: individual's default under ss.152, 155 or 156 draws a penalty up to fifty thousand rupees and a continuing penalty up to five hundred rupees a day.

Test yourself

1. Who allots the DIN, and within what period? The Central Government, within one month of receiving the application under s.153, s.154.

2. Is it an offence merely to hold two DINs without having applied for the second? Yes. Section 155 forbids an individual who already has a DIN to apply for, obtain or possess another, so possession alone offends.

3. Trace the two intimation duties and their time limits. The director intimates his DIN to all companies in which he is a director within one month of receipt, s.156; each company furnishes the DINs of all its directors to the Registrar within fifteen days of that intimation, s.157(1).

4. Which defaults does s.159 penalise, and against whom? Defaults by an individual or director in complying with s.152, s.155 or s.156, with a penalty up to fifty thousand rupees and a continuing penalty up to five hundred rupees a day.

5. Why is the DIN necessary for the enforcement of ss.164 and 165? Because disqualification and the cap on the number of directorships both depend on identifying the same individual across different companies, which a name alone cannot do.