Accounting practices · Table 6, professional services
Last checked 25 September 2026 against the AML/CTF Act compilation C2026C00274, the AML/CTF Rules 2025 (F2025L01026) and the Transitional Rules 2026 (F2026L00393)
Tax returns, BAS and bookkeeping are not designated services. Setting up a company or trust, providing a registered office address, acting as a company officer or trustee, or holding a client's money for a transaction can be. If your practice provides one of those services, it has had AML/CTF obligations since 1 July 2026.
s 6 Sch 3 item 11 AUSTRAC professional designated services
Not sure your practice is regulated? Work through our questions, or use AUSTRAC's tool (AUSTRAC website, opens in a new window).
AUSTRAC's accountant starter kit is free
AUSTRAC publishes a free program starter kit for accounting practices. If your practice fits AUSTRAC's profile and you have time to customise it, it may be all you need. Our accountants edition is built on it, openly and with attribution.
AUSTRAC's accountant starter kit (AUSTRAC website, opens in a new window)
01 Scope
Table 6 in section 6 of the Act lists the professional services that are designated. These are the items an accounting practice is most likely to provide. The summary is ours; the wording of the Act decides.
| Item | The service, in short | Your customer | Accounting example |
|---|---|---|---|
| 2 | Assisting in a transaction to sell, buy or transfer a company, trust or other body corporate or legal arrangement | The person you act for | Acting for a client selling its company, once there is a buyer |
| 3 | Receiving, holding and controlling (including disbursing), or managing, a person's money or property as part of a transaction, unless section 6(5C) applies | The person | Paying a client's bills from money the client sends you |
| 4 | Assisting in equity or debt financing for a company, trust or other body corporate or legal arrangement | The person | Organising finance for a client company |
| 5 | Selling or transferring a shelf company | The buyer or transferee | Supplying ready-made companies |
| 6 | Assisting to create or restructure a company, trust or other body corporate or legal arrangement | The person, plus a new company's beneficial owners and directors, or a new express trust's trustee, settlor and beneficiaries | Registering a company; preparing a trust deed, including for an SMSF |
| 7 and 8 | Acting as, or arranging for someone to act as, a company director or secretary, a partner, a trustee of an express trust or a power of attorney of a body corporate or legal arrangement (item 7), or a nominee shareholder (item 8) | The person you act for (the nominator) | Acting as company secretary for a client |
| 9 | Providing a registered office or principal place of business address | The person you provide it to | Your office as a client company's registered office |
s 6 s 6(5C) AUSTRAC professional designated services
Not designated on their own: preparing tax returns and BAS, payroll and bookkeeping. They are not Table 6 items. Tax advice about selling a company does not start a designated service either, in AUSTRAC's example, until you act on instructions to sell to a buyer. AUSTRAC professional designated services
You decide, and you write the decision down
Whether a service is designated is your practice's decision, made on the Act and AUSTRAC's guidance. Use AUSTRAC's Check if you may be regulated tool (opens in a new window), keep the result, and record your decision service by service. Documents 01 and 26 of the accountants edition are built for that record. Where the answer is unclear, get legal advice.
02 Where practices get caught out
When you create a company, your item 6 customers include its beneficial owners and directors, not just the client who instructs you. When you create an express trust, they include the trustee, settlor and beneficiaries. A beneficial owner is an individual who ultimately owns 25% or more of the entity, or controls it. s 6 s 5
An SMSF is set up through a trust. In AUSTRAC's example, drafting the trust deed and facilitating its execution directly advances the creation of the trust, which is item 6. Advising on the benefits of an SMSF and referring the client to a solicitor does not, on its own. AUSTRAC adds that an adviser with an Australian financial services licence who arranges the set-up may be providing a different designated service, under Table 1. Table 1 services fall outside AUSTRAC's accountant starter-kit profile. AUSTRAC professional designated services
Item 9 applies when a company or trust uses your address in place of an address it operates from. AUSTRAC says the service starts when you make the address available, even before it is lodged with ASIC, and that it does not matter whether you charge for it. s 6 AUSTRAC professional designated services
Receiving a client's money into your account and paying their lease or school fees on their instructions is likely to be item 3, in AUSTRAC's example. Routine payroll and supplier payments made on fixed client instructions are less likely to be. Section 6(5C) excludes payment of your own fees and, if you provide no other designated service, payments reasonably incidental to a service that is not designated. s 6(5C) AUSTRAC professional designated services
03 The accountants edition
The edition holds the 25 program documents every edition has: the risk assessment, the policies, the process document, client due diligence (CDD) forms, registers and the reporting calendar. The kit page lists them all. The accountants wording runs through them: the risk assessment starts from AUSTRAC's accountant risk assessment, and the policies carry the section 123(4) clause. Then come two documents of its own:
Tests each kind of engagement against Table 6 items 2 to 9: company and trust formation, SMSF establishment, registered office, shelf companies, nominee and officer services. It applies the section 6(5C) exclusions and AUSTRAC's worked examples, and records your decision and who the item 6 customers are.
What staff may and may not say to a client once a suspicious matter report is being considered, the good-faith exception for qualified accountants, who decides, and what is recorded.
AUSTRAC's original files are not in our zip. You can download them free from AUSTRAC's accountant kit document library (opens in a new window) and compare them with ours.
Built for the practices AUSTRAC's kit was built for
AUSTRAC designed its accountant kit for practices that only provide professional designated services, have 15 or fewer personnel (counting administrative staff), mostly deal with individual clients who are Australian residents, do not regularly deal with high-risk clients or overseas property, offer no fully remote self-service, are not acquiring another practice or its clients, and are not part of a large reporting group, foreign branch or subsidiary. Outside that profile, AUSTRAC says you "cannot rely on the starter kit to meet AUSTRAC's regulatory expectations". The same goes for our edition, which is built on it. AUSTRAC accountant kit: getting started
04 What the law requires
| Obligation | In short | Law |
|---|---|---|
| Enrolment | Enrol on AUSTRAC's Reporting Entities Roll. You apply directly to AUSTRAC; you do not need us for it. | s 51B |
| AML/CTF program | A written ML/TF risk assessment and AML/CTF policies, documented before your first designated service and approved by a senior manager | s 26B s 26C s 26F s 26P Rules 5-15 |
| Compliance officer | A person at management level who is a resident of Australia and fit and proper, designated within 28 days of your first designated service; AUSTRAC told within 14 days. In a sole practice one person can be the governing body, the senior manager and the compliance officer, and then does not report to themselves. | s 26J s 26K s 26M Rules 5-7 AUSTRAC sole traders and micro businesses |
| Client checks | Before you act, unless the Rules allow a delay: who the client is, their beneficial owners, politically exposed person and sanctions status, and the purpose of the work; then ongoing checks | s 28 s 29 s 30 |
| Reports | Suspicious matters within 3 business days of forming the suspicion (24 hours for terrorism financing); physical currency of A$10,000 or more within 10 business days | s 41 s 43 |
| Records | Kept for 7 years | s 107 s 111 s 116 |
05 Key dates
Program, client due diligence, reporting and record-keeping obligations began for professional services (Table 6).
Enrolment was due for practices already providing a Table 6 service on 1 July 2026. A practice that starts later has 28 days from its first designated service. A missed date does not end the obligation: it continues until you enrol.
Not enrolled yet? You enrol directly with AUSTRAC. You do not need to buy anything from us to do it. Enrol with AUSTRAC (opens in a new window)
AUSTRAC said it had begun issuing section 167 notices to businesses that appear to be providing designated services but have not enrolled. It named accountants among them.
Your first annual compliance-report period ends.
Last day to lodge your first annual compliance report.
First independent evaluation, if you were in the 29 July 2026 enrolment group: before 30 June 2029, 31 December 2029, 30 June 2030 or 31 December 2030, depending on the last two digits of your enrolment identifier.
As at 17 September 2026, AUSTRAC's enrolment table listed 13,780 enrolments under accounting and professional services. AUSTRAC Enrol with us overview
06 Done for you
You pay once, download the full kit straight away, and receive the accountants intake questionnaire. We send your draft documents within 5 business days of receiving your complete intake.
Band 1 · 1–3 personnel
A$990 one-off, includes GST of A$90.00
A sole practitioner or a practice of 1 to 3 personnel, one office, mostly individual clients.
Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.
Band 2 · 4–8 personnel
A$1,490 one-off, includes GST of A$135.45
4 to 8 personnel, with companies and trusts among your clients.
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Band 3 · 9–15 personnel or mixed service lines
A$2,490 one-off, includes GST of A$226.36
9 to 15 personnel, two offices, or an SMSF-heavy practice.
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We do not act as your compliance officer, lodge reports for you or carry out your independent evaluation. If your intake shows your practice is outside AUSTRAC's starter-kit profile or has more than 15 personnel, we tell you and refund you in full before any work starts. Full Setup details · All prices
07 Straight answers
Usually some of these Table 6 items: creating or restructuring a company or trust, including the trust behind an SMSF (item 6); acting on the sale or transfer of a company or trust (item 2); providing a registered office or principal place of business address (item 9); acting as, or arranging, a director, secretary, trustee or nominee shareholder (items 7 and 8); selling shelf companies (item 5); and receiving, holding or managing client money as part of a transaction, unless an exclusion in section 6(5C) applies (item 3). Tax returns, BAS, payroll and bookkeeping are not Table 6 items. s 6 s 6(5C)
Not by those services, because they are not Table 6 items. The test runs service by service. In AUSTRAC's bookkeeper example, routine payments made on fixed client instructions are less likely to be item 3. Use AUSTRAC's Check if you may be regulated tool (opens in a new window) and keep a written record of your decision. If you later start a Table 6 service, enrolment is due within 28 days of your first designated service. s 51B
For item 6, the customer is the person you assist. When you create a company, it also includes the company's beneficial owners and directors. When you create an express trust, it also includes the trustee, settlor and beneficiaries. The accountants edition's forms are built for those extra people. s 6
The tipping-off offence covers disclosing that a suspicious matter report has been made or must be made, where that would or could reasonably be expected to prejudice an investigation. Section 123(4) creates an exception for a qualified accountant who discloses in good faith to dissuade a client from conduct that is, or could be, an offence. A qualified accountant is a member of CPA Australia, CA ANZ or the IPA, or of a body specified in the Rules. If you rely on the exception, you carry the burden of pointing to evidence for it, so record what you said and why. s 123 s 5
A sole practitioner or a practice of 1 to 3 personnel with mostly individual clients: Band 1. A practice of 4 to 8 with companies and trusts among its clients: Band 2. A practice of 9 to 15, two offices, or an SMSF-heavy practice: Band 3. If you are unsure, email [email protected] with your headcount and services before you pay.
A worksheet for deciding which of your services are designated, covering company and trust formation, SMSF establishment, registered office, shelf company, nominee and officer services, with the section 6(5C) exclusions. A tipping-off procedure with the section 123(4) exception written in. The law behind each obligation written into every document. A training register, a pre-commencement customer register, a record-keeping index and a one-page reporting and review calendar. The kit page compares the two side by side.
More detail: AML/CTF guides and the sources we rely on.
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