Tranche 2 essentials
AML/CTF Tranche 2, explained for small businesses (2026)
What Australia's AML/CTF Tranche 2 reforms mean for small businesses: who's captured, the key 2026 dates, what you actually have to do, and where to start — in plain English, checked against AUSTRAC.
If you run a law practice, accounting firm, conveyancing business, real estate agency or deal in precious metals and stones, the question on your desk right now is simple: does Tranche 2 apply to me, and what do I have to do before 1 July 2026? This guide answers exactly that, in plain English, with every date and figure checked against AUSTRAC.
What "Tranche 2" actually is
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Act No. 110, 2024) extends Australia's AML/CTF regime to a group of professions that have never had to comply before. The Bill passed Parliament on 29 November 2024 and the Act received Royal Assent on 10 December 2024 — the 29 November date you may have seen quoted is the passage date, not assent. The amending Act sits on top of the principal AML/CTF Act 2006, which remains the core law. (Sources: Federal Register of Legislation, C2024A00110.)
AUSTRAC — the financial intelligence regulator — describes this as the most significant overhaul of Australia's AML/CTF framework in more than 20 years.
How big is the change?
AUSTRAC states that from 1 July 2026 the number of businesses it regulates will grow from around 19,000 to close to 100,000 nationwide — roughly 80,000-plus newly regulated businesses, most of them small and medium firms new to AUSTRAC. (You'll often see "90,000–100,000 newly regulated" quoted; AUSTRAC's own current framing is the 19,000-to-100,000 jump, so we use that. Source: AUSTRAC opens enrolment for new professions.)
Who is captured?
The newly regulated sectors from 1 July 2026 are:
- Real estate professionals (agents, buyer's agents, property developers)
- Conveyancers
- Lawyers and legal practitioners
- Accountants
- Dealers in precious metals, stones and products
- Trust and company service providers (TCSPs)
The crucial point AUSTRAC repeats: capture is service-based, not occupation-based. You are a reporting entity only if you provide a "designated service" listed in the Act and there's a geographical link to Australia. A solicitor who never touches a designated service may not be captured at all. (Source: AUSTRAC — new industries and services to be regulated.) To work out your own position, see Is my business an AUSTRAC reporting entity?
The dates that matter
| Date | What happens |
|---|---|
| 31 March 2026 | AUSTRAC Online enrolment opened for newly regulated entities (can't enrol earlier) |
| 1 July 2026 | New AML/CTF obligations commence for Tranche 2 sectors |
| 29 July 2026 | Deadline to apply to enrol (28 days after commencement) |
| Later of 29 July 2026 or 14 days after enrolling | Deadline to notify AUSTRAC of your AML/CTF compliance officer |
There's a full breakdown in Tranche 2 key dates: 1 July and 1 October 2026. (Sources: AUSTRAC summary of obligations; AUSTRAC AML/CTF transitional rules 2026.)
What you actually have to do
If you're captured, your core obligations from commencement are:
- Enrol with AUSTRAC (one enrolment per business, via the AUSTRAC Online Business Profile Form).
- Implement an AML/CTF program — under the reformed regime that means an ML/TF (and proliferation-financing) risk assessment, AML/CTF policies, and a governance framework. The old rigid Part A / Part B split is gone.
- Appoint an AML/CTF compliance officer and notify AUSTRAC.
- Conduct customer due diligence (CDD/KYC) — initial and ongoing, risk-based, with enhanced CDD for higher-risk situations.
- Report suspicious matters (SMRs) and threshold transactions (cash of A$10,000 or more), and keep records for 7 years.
(Source: AUSTRAC summary of obligations.)
Your AML/CTF program and compliance officer generally need to be in place before you provide a designated service — so the practical deadline is 1 July 2026, not 29 July. There's a step-by-step in How to do an ML/TF risk assessment.
Where to start
Don't over-engineer it, and don't panic-buy a consultant before you know whether you're even captured. The sensible order is:
- Confirm whether your services are designated services (start with the free tool below).
- If captured, scope your ML/TF risk assessment.
- Build a proportionate program — AUSTRAC stresses it should match the nature, size and complexity of your business.
- Enrol and appoint your compliance officer.
General information only. This guide reflects AUSTRAC guidance and the AML/CTF Act 2006 current to June 2026. Dates and figures can change — confirm your obligations with AUSTRAC (austrac.gov.au) or a qualified adviser before acting.
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