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 cash transactions at or above the threshold.
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 independent evaluations on the cycle set by the Rules.
The obligations, in the order you meet them
- Enrol with AUSTRAC within 28 days of first providing a designated service.
- Adopt a written AML/CTF program: a risk assessment of your business plus the policies you follow.
- Appoint an AML/CTF compliance officer at management level.
- Verify every client, and the beneficial owners of any company or trust, before providing the service.
- Rate and review client risk on a schedule.
- Report suspicious matters within three business days and cash of AU$10,000 or more within ten; lodge an annual compliance report.
- Keep records for seven years.
- 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 stated approach to the first period is education and guidance, with enforcement reserved for businesses that ignore the regime rather than those making a genuine effort. That does not mean the deadlines are optional: a firm with no enrolment, no program and no client identification is the profile enforcement looks for.
Questions people ask
- What does Tranche 2 mean?
- The second group of businesses brought into Australia's AML/CTF regime: accountants, bookkeepers, real estate agents, lawyers, conveyancers, trust and company service providers and dealers in precious metals and stones. Their obligations commenced on 1 July 2026.
- Is there a Tranche 3?
- Not announced. The 2024 amendments completed the expansion that international standards required. Future changes are more likely to refine the current regime than to add a new tranche.
- I am a sole practitioner. Does Tranche 2 apply to me?
- If you provide a designated service, yes. The obligations attach to the service, not to the size of the business. A sole practitioner's program is simply shorter.
- What happens if I missed the 28-day enrolment window?
- Enrol now. Late enrolment is better than none, and AUSTRAC's early focus is on businesses that make no effort at all.
General information about Australian AML/CTF law, not legal advice. The Act, the Rules and AUSTRAC's guidance are the primary sources.