In short
- Since 1 July 2026 the AML/CTF Act has applied to firms that provide certain real estate and professional services, and to dealers in precious metals and stones.1
- Whether you are covered depends on the services you provide. Your job title and the size of your firm do not decide it.
- If you are covered, you must enrol, designate a compliance officer, have a documented risk assessment and policies before you act for a client, check your clients, report, keep records, lodge a compliance report each year and have your program independently evaluated.
- Enrolment was due on 29 July 2026 for firms already providing those services. In August 2026 AUSTRAC began issuing notices to businesses that appear to be providing them without enrolling.7
What the 2024 Act did
"Tranche 2" is the common name for this expansion. It is not a term the Act uses. The changes came from the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, which took effect in stages.2
| Date | What happened | Source |
|---|---|---|
| 31 March 2026 past | Schedules 1 to 3 commenced. Among other changes they rewrote Part 1A (the AML/CTF program) and Part 2 (customer due diligence). The detail now sits in the AML/CTF Rules 2025. | Amendment Act s 2 |
| 1 July 2026 past | Schedule 4 (legal professional privilege) commenced. The program, due diligence, reporting and record-keeping obligations began to apply to the newly covered sectors. | Amendment Act s 2 Sch 3 item 11 |
| 29 July 2026 past | Enrolment was due for firms already providing a covered service on 1 July 2026. | Sch 3 item 12 |
Under the rewritten Part 1A, an AML/CTF program is two things: your ML/TF risk assessment and your AML/CTF policies.3 If a template you hold is organised differently, or cites the Rules by chapter, its references are likely out of date.
Who it brought in
From 1 July 2026 the obligations applied to three groups of services, all listed in section 6 of the Act.1
- Real estate (Table 5). Brokering the sale, purchase or transfer of real estate for a buyer or seller, which covers selling agents and buyer's agents. The agent's customer is both the seller and the buyer. Selling your own real estate in a business of selling real estate, without an independent agent, is also covered (item 2, for example developers).
- Professional services (Table 6). Nine items, including acting in a sale or purchase of real estate (conveyancing), buying or selling a company or trust, holding or managing a client's money or property for a transaction, setting up or restructuring a company or trust, acting as or arranging a director, secretary, trustee or nominee shareholder, and providing a registered office address.
- Dealers in precious metals and stones (Table 2, item 2). The kit on this site does not cover dealers; see the dealers guide.
Plenty of everyday work is outside these tables. Preparing tax returns, BAS and payroll are not listed services, and the Act excludes, for example, money you receive as payment of your own fees, and leases of 30 years or less. Check where you sit in Is my business a reporting entity? and What is not a designated service.
| Sector | Enrolled |
|---|---|
| Real estate | 18,350 |
| Accounting and professional services | 13,780 |
| Lawyer | 6,580 |
| Conveyancer | 1,600 |
| Jewellers and dealers in precious metals and goods | 320 |
Source: AUSTRAC, "Enrol with us overview".8 AUSTRAC table
Where enrolment and enforcement stand
Enrolment. If you were already providing a covered service on 1 July 2026, enrolment was due by 29 July 2026.4 If you started later, you must apply within 28 days of first providing the service.5 s 51B(1)
Late is still an obligation. It continues until you apply, and each day after the deadline is a separate contravention.5 s 51B(2B)–(2C) Failing to enrol is a civil penalty provision. It is also a provision for which an infringement notice can be given: the Act sets 60 penalty units for a body corporate and 12 for anyone else, unless the AML/CTF Rules set a different number for the kind of contravention (up to 120 and 24). At the $364 penalty unit that has applied since 1 July 2026, 60 and 12 units are $21,840 and $4,368.6
The ceiling. The maximum civil penalty a court can order is 100,000 penalty units ($36.4 million) for a body corporate and 20,000 penalty units ($7.28 million) for anyone else.6 s 175(4)–(5) These are maximums, not typical outcomes.
AUSTRAC's stated approach. On 1 July 2026 AUSTRAC wrote: "We will take a pragmatic and proportionate approach as businesses transition to the new requirements. However, reporting entities are expected to continue actively managing their ML/TF risks and work towards full compliance."9
Notices. On 28 August 2026 AUSTRAC said it "has begun issuing section 167 notices to businesses that appear to be providing designated services but have not enrolled", naming real estate agents, accountants, lawyers and jewellers. Its chief executive said: "The time for preparation has passed."7 A section 167 notice is a written notice from an authorised officer requiring information or documents.10 s 167
Not enrolled yet?
Apply now. You enrol directly with AUSTRAC through AUSTRAC Online, and you do not need to buy anything from us to do it. Enrol with AUSTRAC
If you are unsure about your position for the period you were not enrolled, get legal advice.
What a small firm must have
Size does not change whether these obligations apply. It does change how much your risk assessment and policies need to say, because they must deal with the risks your business may reasonably face.3
| Obligation | What it means in practice | Where |
|---|---|---|
| Enrol | Apply within 28 days of starting (29 July 2026 if you were already providing the service). Tell AUSTRAC of changes within 14 days. | s 51B s 51F |
| Compliance officer | Designate one within 28 days of starting: someone at management level, a resident of Australia and a fit and proper person. Notify AUSTRAC within 14 days. | s 26J s 26K s 26M |
| Risk assessment | Identify and assess your money laundering, terrorism financing and proliferation financing risks, considering your services, clients, delivery channels and the countries you deal with. Review it when something significant changes and at least every 3 years. Do not start a service without it. | s 26C s 26D s 26E |
| Policies | Policies, procedures, systems and controls that manage those risks, covering client due diligence, staff screening and training, independent evaluation and more. Review them at least every 3 years, and follow them. | s 26F s 26G |
| Approval and oversight | A senior manager approves the risk assessment and policies, and every update. Your governing body oversees them. | s 26P s 26H |
| Written down first | Document the program before your first designated service, and document each update within 14 days. | s 26N Rules 5-15 |
| Client due diligence | Before you act, establish who the client is (and any beneficial owners), whether they are a politically exposed person or sanctioned, and why they are engaging you. Verify using reliable and independent data suited to the risk. Monitor clients as you go. | s 28 s 30 s 32 |
| Suspicious matters | Report within 3 business days of forming the suspicion; 5 business days where some (not all) of the information may be privileged and the privilege belongs to someone else; 24 hours for terrorism financing. | s 41(2) |
| Cash of $10,000 or more | Report the threshold transaction within 10 business days. | s 43 s 5 |
| Compliance report | First period 1 July 2026 to 30 June 2027. Lodge it in AUSTRAC's approved online form between 1 July and 30 September 2027. | s 47 Rules 9-9 |
| Records | Keep them for 7 years. When the clock starts depends on the kind of record. | s 107 s 108 s 111 s 116 |
| Independent evaluation | As often as your policies say, and at least once every 3 years, by someone independent. If your enrolment was due on 29 July 2026, the first one is on time if done before a date in 2029 or 2030 set by your enrolment identifier. If you started later, your policies set the first date. | s 26F(4)(f) Rules 5-10 Transitional Rules s 17 |
Two rules soften the start for existing work. Clients you were already acting for at the start of 1 July 2026 are "pre-commencement customers": initial due diligence does not apply to them until a suspicious matter reporting obligation arises, or the relationship changes significantly and their risk becomes medium or high.11 And in real estate transactions, initial due diligence can in some cases be completed after the service starts, within the window in Rules 6-32.11
Dates still ahead
| Date | What | Source |
|---|---|---|
| 30 June 2027 | End of the first compliance-report period, which began 1 July 2026. | Rules 9-9 |
| 1 July to 30 September 2027 | Lodge your first compliance report. | s 47 Rules 9-9 |
| 30 June 2029 to 31 December 2030 | First independent evaluation, if your enrolment was due on 29 July 2026: before a date set by the last two digits of your enrolment identifier. Firms that started later follow their own policies (at least once every 3 years). | s 26F(4)(f) Transitional Rules s 17 |
The full list, including the evaluation table, is in Tranche 2 key dates.
What it is likely to cost
The government's Impact Analysis (September 2024) estimated that the smallest businesses, with turnover up to $200,000, would face about $4,460 in upfront costs and about $6,020 in ongoing costs each year.12 Impact Analysis, Table 19 The department also noted that these businesses "would not be 'starting from scratch'", and the figures are estimates of additional cost.
You do not have to pay anyone to start. AUSTRAC publishes free program starter kits for accountants, conveyancers, jewellers, legal practices and real estate businesses.13 Our AML/CTF kit (A$497) is built on those kits, and our Set-up service (from A$990) tailors it to your firm. Both are one-off prices including GST. More in what compliance costs a small firm.
What to do next
Check your services
Compare what you actually do with Tables 5 and 6, using Is my business a reporting entity? or the free check.
Enrol if you have not
Directly with AUSTRAC. Late enrolment is still required.
Designate your compliance officer
Then notify AUSTRAC within 14 days.
Write the risk assessment, then the policies
Have a senior manager approve both before you act for a client. Start from AUSTRAC's free starter kit for your sector, or from our kit.
Put it into daily practice
Client checks, reporting and records. Diarise the compliance report and your first evaluation. The obligations checklist lists each one with its section.
For your sector: accounting practices · real estate agencies · conveyancers · legal practices. All guides are listed on the guides page, and every source we use is on the sources page.
Independent. Not affiliated with, or endorsed by, AUSTRAC or the Australian Government.
Sources
Law is quoted from the authorised text on the Federal Register of Legislation, opened 25 September 2026. AUSTRAC pages are guidance, not law. They open in a new window, and linking to them does not mean AUSTRAC endorses this page.
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AML/CTF Amendment Act 2024 (C2024A00110), Schedule 3, item 11(1). AML/CTF Act s 6, Table 2 item 2, Table 5 and Table 6. legislation.gov.au/C2006A00169/latest/text
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AML/CTF Amendment Act 2024 (C2024A00110), s 2 (commencement table). legislation.gov.au/C2024A00110/latest/text
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AML/CTF Act ss 26B, 26C(1) and (3), 26F(1).
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AML/CTF Amendment Act 2024, Schedule 3, item 12.
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AML/CTF Act s 51B(1), (2B), (2C) and (3).
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AML/CTF Act ss 184(1A), 186A(1)–(2) and (5), 175(4)–(5). Crimes (Amount of a Penalty Unit) Instrument 2026 (F2026N00424), s 5: a penalty unit is $364 from 1 July 2026. Dollar amounts are our arithmetic. legislation.gov.au/F2026N00424/latest/text
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AUSTRAC, "AUSTRAC issues notices to non-enrolled businesses", 28 August 2026 (guidance). austrac.gov.au
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AUSTRAC, "Enrol with us overview", enrolment table as of 17 September 2026 (guidance). austrac.gov.au
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AUSTRAC, "Changes to AML/CTF obligations: What you need to do", 1 July 2026 (guidance). austrac.gov.au
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AML/CTF Act s 167.
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AML/CTF Act ss 28, 29 and 36. AML/CTF Rules 2025 (F2025L01026), rule 6-32. legislation.gov.au/F2025L01026/latest/text
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Office of Impact Analysis, Impact Analysis for the AML/CTF reforms (Attorney-General's Department, September 2024), Table 19 (estimate). oia.pmc.gov.au
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AUSTRAC, "Program starter kits" (guidance). austrac.gov.au