Who has to enrol
The AML/CTF Amendment Act 2024 brought accountants into the regime as Tranche 2 entities. Obligations start on 1 July 2026. A firm becomes a reporting entity the moment it provides a designated service, regardless of its size or whether it is a sole practitioner.
- Receiving, holding or controlling client money, securities or other assets (not simply receiving fees).
- Assisting a client to plan or carry out the purchase or sale of real estate or a business.
- Creating, operating or managing a company, trust or partnership for a client, including acting as a registered office or nominee.
- Organising contributions for those entities.
Who does not
A practice that only prepares tax returns, financial statements and BAS, gives tax advice and does bookkeeping in the client's own systems does not provide a designated service and does not need to enrol. Watch for the edge cases: holding a deposit for a client, arranging a company for a client through ASIC, or running a client's trust account crosses the line.
When and how
Enrolment opened on 31 March 2026. You must enrol within 28 days of first providing a designated service, so a firm already doing this work needed to enrol by 29 July 2026. Enrolment is done through AUSTRAC Online, is free and asks for your business details, the designated services you provide and your compliance officer.
What enrolment commits you to
- An AML/CTF program, adopted before you provide the services.
- Customer due diligence on every client, including beneficial owners.
- Suspicious matter, threshold transaction and annual compliance reports.
- Records kept for 7 years.
- Staff training and a compliance officer.
Questions people ask
- I am a sole practitioner. Do I still need to enrol?
- Yes, if you provide a designated service. The obligations attach to the service, not to the size of the firm.
- Does enrolling cost anything?
- No. AUSTRAC enrolment is free. The cost is in meeting the obligations that follow.
- What if I am not sure whether a service is designated?
- Read AUSTRAC's guidance for accountants, and if still unsure get advice. Enrolling when you did not need to is a nuisance; providing a designated service without enrolling is a breach.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.