It might be true that

* There may be no basis in the policy for insisting on an ABN for 
applications under 1.c)  but is it implied?
 
* In the past their was certainly now requirement (and I have put a 
few domains like this i.e. my own king.com.au )

BUT

Speaking to the people at Enetica they basically said that even if my 
client is eligible policy wise (and very doubtful they seem re this) 
on technical level they must fill in the (ACN, ABN, Registered 
business number) field with something.

Any thoughts would be appreciated, particularly from anyone from AUDA.

Matthew King