Is my business a reporting entity?

The test

A reporting entity is "a person who provides a designated service".¹ s 5 The designated services are listed in tables in section 6 of the Act. For the businesses this site serves, the tables that matter are Table 5 (real estate) and Table 6 (professional services).²

For a listed service to catch you:

• you provide it. Each item describes an activity, such as brokering a sale or setting up a trust, not a profession. A conveyancer, a lawyer and an accountant who all set up a trust are providing the same service;
• in the course of carrying on a business. Every item in Tables 5 and 6 says this;
• with a link to Australia. Usually the service is provided at or through a permanent establishment in Australia.³ s 6(6)

Common services and where they sit

The full wording of each item decides. Read it before you rely on this summary.² s 6

Real estate agencies and developers

Table 5, item 1 covers "brokering the sale, purchase or transfer of real estate on behalf of a buyer, seller, transferee or transferor in the course of carrying on a business". The customer is both the seller and the buyer, so an agent acting only for the vendor still has obligations towards the buyer.²

Item 2 covers selling or transferring real estate in a business of selling real estate, where the sale is not brokered by an independent agent. AUSTRAC gives developers selling house-and-land packages, off-the-plan apartments and lots in new subdivisions as examples.⁴

"Real estate" includes freehold, leasehold interests and land use entitlements, but a lease for 30 years or less is excluded.⁵ s 5 Arranging ordinary residential and commercial leases is therefore not brokering real estate. Property management is dealt with in What is not a designated service.

AUSTRAC's view of when the service starts: a seller's agent starts providing it to the seller when the agency agreement is signed, and to the buyer when it is reasonably expected the sale will proceed, typically when the offer is accepted and the contract is signed.⁴ AUSTRAC, real estate designated services

More for agencies: AML/CTF for real estate agencies.

Conveyancers and legal practices

Table 6, item 1 covers assisting a person in the planning or execution of a transaction to sell, buy or otherwise transfer real estate, or acting for them in it, in the course of a business. It does not apply where the transfer is pursuant to, or results from, a court or tribunal order.² That is the core of conveyancing, whether done by a conveyancer or a law practice.

Holding a client's money in trust for the transaction and controlling when it is paid out is a separate item: Table 6, item 3. Item 3 has its own exclusions in s 6(5C), for example for money that is payment of your own fees.⁶ s 6(5C)

Legal practices commonly also provide:

• item 2: acting in the sale or purchase of a company, trust or other legal arrangement;
• item 4: organising equity or debt financing for a company or trust;
• item 6: setting up or restructuring a company or trust;
• items 7 to 9: acting as, or arranging, a director, secretary, trustee or nominee, and providing a registered office address.

A barrister's work on a solicitor's instructions given in connection with a designated service is not itself a designated service.⁷ s 6(6B) AUSTRAC's view is that litigation will generally fall outside Table 6.⁸

More: conveyancing practices and legal practices.

Accounting practices

The Table 6 items most often met in accounting practices are item 6 (registering a company, or drafting and settling a trust deed), item 9 (your office as a client's registered office), item 7 (acting as company secretary or trustee for a client), item 3 (holding a client's money for a transaction) and item 2 (acting on the sale of a client's business entity).²

Preparing tax returns, BAS and payroll are not listed services.² AUSTRAC's worked examples draw the line this way:⁸

• tax advice on the implications of selling a company is not item 2, but once the firm is instructed to act for the client in the sale, the service begins;
• a practice that receives a client's money into its own account and pays the client's lease and school fees on their instructions is likely to be providing item 3, unless an exclusion applies.

More: AML/CTF for accounting practices.

Dealers in precious metals and stones

Dealers in precious metals and stones are covered by Table 2, item 2, and have been since 1 July 2026.⁹ The kit on this site does not cover dealers. See the dealers guide.

If one of these is yours

You are a reporting entity. If you were already providing the service on 1 July 2026, enrolment was due by 29 July 2026; if you started later, you must apply within 28 days of first providing it.¹⁰ s 51B(1) Sch 3 item 12

A late application is still required. The obligation continues until you apply, and each day after the deadline is a separate contravention. Failing to enrol can also lead to an infringement notice of 60 penalty units for a body corporate or 12 for anyone else ($21,840 or $4,368 at the $364 penalty unit).¹¹ On 28 August 2026 AUSTRAC said it had begun issuing section 167 notices to businesses that appear to be providing designated services without enrolling, naming real estate agents, accountants, lawyers and jewellers.¹² AUSTRAC has also said it will take a "pragmatic and proportionate approach" while businesses transition, and expects them to keep managing their risks and work towards full compliance.¹⁵

Then designate a compliance officer, and document your risk assessment and policies before you next act for a client. The tranche 2 guide lists every obligation with its section. Our kit (A$497) is built on AUSTRAC's free starter kits for your sector, and our Set-up service (from A$990) tailors it to your firm.

If none of these is yours

Our suggestion: write a short file note listing the services your firm provides and why none is a listed item, and look at it again whenever you add a service. It is useful if you are ever asked. The Act lets AUSTRAC require information to work out whether a business provides designated services.¹³ s 202

Two tools help you check:

• AUSTRAC's own "Check if you may be regulated" pages, with worked examples for each sector.¹⁴
• Our free six-question check, which shows the Table 5 or Table 6 items that may apply to you.

If a service sits close to the line, read What is not a designated service. If you are still unsure, ask a lawyer.

Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.

All guides: guides. Every instrument and AUSTRAC page we cite: sources.