Tranche 2 explained: the 2026 AML/CTF reforms for accountants, real estate agents, lawyers and conveyancers

Who is in Tranche 2

The trigger is always the service, not the profession. A litigator or a tax-only accountant who provides none of the designated services is not a reporting entity.

• Accountants and bookkeepers who provide designated services such as managing client money, helping to set up or manage companies and trusts, or assisting with the sale or purchase of real estate or a business.
• Real estate agents and buyers agents who broker the sale, purchase or transfer of real estate, and developers who sell direct.
• Lawyers and conveyancers who act in property or business transactions, hold client money, or create and manage companies and trusts.
• Trust and company service providers.
• Dealers in precious metals and stones, for transactions of AU$10,000 or more in physical currency or virtual assets.

The key dates

• 31 March 2026: enrolment opens for Tranche 2 entities; new rules commence for existing (Tranche 1) reporting entities and virtual asset providers.
• 1 July 2026: Tranche 2 obligations commence. A business providing a designated service on that date must enrol within 28 days, by 29 July 2026.
• Ongoing: annual compliance reports, program reviews, and an independent evaluation of the program at least once every three years.

The obligations, in the order you meet them

1. Enrol with AUSTRAC within 28 days of first providing a designated service, and notify any change to your details within 14 days.
2. Adopt a written AML/CTF program: a risk assessment of your business plus the policies you follow, approved by a senior manager.
3. Appoint an AML/CTF compliance officer at management level within 28 days of first providing a designated service, and notify AUSTRAC within 14 days of the appointment.
4. Identify and verify every customer, and the beneficial owners of any company or trust, before providing the service. The Rules allow a delay only in limited cases, such as a buyer who is unknown until an auction ends.
5. Rate and review client risk on a schedule.
6. Report suspicious matters within three business days and cash of AU$10,000 or more within ten; lodge an annual compliance report.
7. Keep records for seven years.
8. Train staff on commencement and regularly.

Where to go for your sector

This guide covers the regime in general. For a sector-specific walkthrough, checklists and a program template, see the sister sites: LedgerAML for accountants and bookkeepers, RealtyAML for real estate agents, PracticeAML for law firms and conveyancers. All three are part of the same group as this guide, and all three run a compliance tool built for firms of one to ten people. The regime also applies to sectors those sites do not cover, such as dealers in precious metals and stones; AUSTRAC publishes guidance for each.

How AUSTRAC has said it will supervise

AUSTRAC's published regulatory expectations for 2025–26 say it will support new entities with tailored guidance, starter programs and education, and that after 1 July 2026 it will prioritise enforcement against entities that wilfully ignore the obligation to enrol or are complicit with, or wilfully blind to, money laundering. That does not make the deadlines optional: a firm with no enrolment, no program and no client identification is the profile enforcement looks for.