Yep, it's a messed up system. You would think that if you had supplied the information to get the initial ASIC, that that fact would be enough to tick the box for the renewal. Same with a passport. If it's been expired for more than three years then you go through the whole rigmarole again. I mean if they gave you a passport once, surely that fact should flag that they've seen your birth certificate.
There is no mention of ASIC renewals in the regs. They are all effectively treated as new applications every 2 years, as that has been deemed the time between background checks that is acceptable. The only (very indirect) reference to renewals in the Auscheck Regulations is that they may charge a higher fee for an initial background check than for a subsequent check.