Updates · 01 July 2026

Tranche 2 obligations commenced on 1 July 2026: what a small firm should have in place now

The second tranche of Australia's AML/CTF reforms took effect on 1 July 2026. Businesses that provide a newly designated service are now reporting entities and must enrol with AUSTRAC within 28 days of first providing it.

Source AUSTRAC — New AML/CTF Rules: key dates

What changed on the day

  • Accountants, bookkeepers, real estate agents, buyers agents, lawyers, conveyancers, trust and company service providers and dealers in precious metals and stones became reporting entities for their designated services.
  • The 28-day enrolment window started for businesses already providing those services, ending 29 July 2026.
  • Customer due diligence, reporting and record-keeping obligations apply from the first designated service provided on or after the date.

What to have in place

  1. Enrolment with AUSTRAC.
  2. An adopted AML/CTF program with a risk assessment and policies.
  3. A named compliance officer, appointed within 28 days and notified to AUSTRAC within 14 days of the appointment.
  4. A client identification process running for every new matter.
  5. Staff trained and the training recorded.

AUSTRAC's stated approach

AUSTRAC's regulatory expectations for 2025–26 promise tailored guidance, starter programs and education for new entities, and say enforcement after 1 July 2026 will be prioritised against entities that wilfully ignore the obligation to enrol or are complicit with, or wilfully blind to, money laundering. Read that as a grace on tone, not on deadlines.

Questions people ask

I started providing designated services after 1 July. When do I enrol?
Within 28 days of the first service. The window runs from your start date, not from 1 July.

Sources

Official AUSTRAC guidance this page was checked against. The date is when we captured the page; AUSTRAC may have updated it since.

Tranche 2 obligations commenced on 1 July 2026: what a small firm should have in place now · AML/CTF Guide