What AML/CTF compliance costs a small firm

The Government's estimate

Before the reforms passed, the Attorney-General's Department published an Impact Analysis with modelling by Nous Group. Its Table 19 estimates the average cost per newly regulated ("tranche two") business, by annual turnover.¹

Impact Analysis, Table 19

Read these figures with the department's own cautions:

• They are averages from modelling, not quotes, and not a forecast for your firm.
• The department said businesses "would not be 'starting from scratch'", and that the figures estimate the additional upfront and ongoing costs.²
• The modelling costed staff time. Businesses surveyed estimated the hours each obligation would take, and those hours were priced at average wage rates.³ That time is still spent whichever route you choose.
• The modelling was done in 2024, before the AML/CTF Rules 2025 and AUSTRAC's starter kits were published. The department said the results did not reflect later work on the Rules and AUSTRAC guidance to find ways to reduce costs further.²

Where the work goes

Table 19 also splits each figure by obligation. For the two smallest turnover bands:

Impact Analysis, Table 19

The department said the costs are "primarily associated with designing and implementing an AML/CTF program and CDD process".² In plain terms:

• The program is your risk assessment and your policies.⁴ It has to be written before your first designated service, approved by a senior manager, and reviewed at least once every 3 years.⁵ The Impact Analysis also counts staff training, staff checks and program reviews here.²
• Client due diligence means checking each client before you act and monitoring them afterwards.⁶ For a busy practice, this is the cost that grows with the number of clients.
• Reporting covers suspicious matter reports, threshold transaction reports and the annual compliance report.⁷ Record-keeping means keeping records for the 7-year periods the Act sets.⁸

What AUSTRAC's free starter kits give you

AUSTRAC publishes five free program starter kits: for accountants, conveyancers, jewellers, the legal profession and real estate. The accountant and real estate kits are at release 1.1, dated 10 June 2026.⁹ You can download them from AUSTRAC's program starter kits page. AUSTRAC links on this page open in a new window. AUSTRAC has not reviewed or endorsed this guide.

The kits are designed for firms that fit a profile. For the accountant, legal and real estate kits, the criteria include:¹⁰

• 15 or fewer personnel, counting administrative staff;
• mostly individual clients who are Australian residents;
• not regularly dealing with high-risk clients;
• no work on overseas property (the real estate kit says: no brokering of overseas property);
• no fully remote self-service options for clients;
• not part of a large reporting group, foreign branch or subsidiary.

AUSTRAC says that if you are outside the profile, "you cannot rely on the starter kit to meet AUSTRAC's regulatory expectations". It also says its guidance "isn't a substitute for legal advice".¹⁰ The conveyancer kit has its own criteria on its page; read them there.

If your firm fits the profile and you have time to tailor the documents yourself, the free kits may be all you need.

What no fixed fee covers

Whoever writes your program, some costs stay with your firm:

• The independent evaluation. It must be carried out at least once every 3 years, by someone independent of whoever wrote your program. The evaluator reports in writing to your governing body and your approving senior manager.¹¹ If the 29 July 2026 enrolment rule applied to you, the first one is due before a date between 30 June 2029 and 31 December 2030, set by your enrolment identifier.¹²
• Screening services. Before acting, you must establish whether a client, and certain people connected with it, is a politically exposed person or designated for targeted financial sanctions.⁶ Some firms pay for screening subscriptions to do this.
• The ongoing work. Checking and monitoring clients, training staff, the compliance officer's time, and lodging reports.
• Legal advice on whether a particular service is captured.

Our prices, and how they compare

We sell two things, each for a one-off fixed price including GST. There are no subscriptions, memberships or renewals.

The kit does not include AUSTRAC's original starter-kit files; you download those free from AUSTRAC. The set-up service includes the kit and is offered to all four sectors, including legal practices, with privilege handling included in every band. Our pricing page sets out what each option includes.

How they compare: for the smallest firms, Table 19's average program cost is A$3,400 upfront. That figure covers the whole modelled effort of building a program, including your own staff time. Our fee is for documents, or for set-up help. It does not replace your time on approvals, training and client checks, and it does not cover the independent evaluation.

We do not act as your compliance officer, lodge reports for you or give legal advice. If you find a factual error in a citation, date or threshold in our documents, we correct it within 5 business days at no cost.

Budget in four steps

1. Check whether you fit AUSTRAC's starter-kit profile

   If you do not, a kit built on the starter kits is not enough on its own. Budget for tailored help or legal advice.

2. Choose your route

   The free AUSTRAC kits and your own time; our kit; our set-up service; or a lawyer or consultant.

3. Budget staff time for client checks

   This is the cost that grows with your client numbers. s 28 s 30

4. Put the independent evaluation in a future year's budget

   It must be independent, so it is a separate cost from whoever writes your program. s 26F(4)(f) Transitional Rules s 17

Where to go next

• Your sector: accounting practices, real estate agencies, conveyancers and legal practices.
• Dates to plan around: our key dates page.
• Every source we use is on our sources page. More guides are on the guides page.

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