AML/CTF Tranche 2 for Accountants in Australia: What Changes on 1 July 2026

Who Is Captured: Accountants, Tax Agents, Bookkeepers

Tranche 2 brings accountants and other professional service providers into Australia's AML/CTF regime for the first time. The shift sounds dramatic, but the structure of the law is narrow on its face: the trigger is the service a practitioner provides on a file, not the practitioner's professional title.

That distinction matters a lot in practice. An accountant who spends a Tuesday morning on three sets of company tax returns, two BAS reconciliations and a Div 7A minute is not providing a designated service. The same accountant, that Tuesday afternoon, setting up a discretionary trust with a corporate trustee for a client buying a commercial property, is providing a designated service. From 1 July 2026 that afternoon's work needs to sit inside an AML/CTF program, with a CDD file on the client, sanctions screening, and a recorded risk assessment.

The legal source is the AML/CTF Act, which AUSTRAC explains in its Professional designated services guidance. The sector-specific landing page is AUSTRAC's Accountants industry page. Both confirm that accountants, registered tax agents, bookkeepers, lawyers, insolvency practitioners and financial advisers are captured to the same extent and on the same legal test.

Two practical points follow. First, your service mix determines whether you enrol at all. A bookkeeper who does data entry, payroll and BAS work is generally outside the regime. A bookkeeper who occasionally also sets up companies or holds client funds for a transaction has crossed into the new regime. Second, once any of your work is captured, the obligations apply to your firm, not just to that file. You need a program covering the captured work, and you need to enrol the entity that provides the service.

The Nine Professional Designated Services

AUSTRAC's Professional designated services guidance sets out items 1 to 9 of table 6 of subsection 6(5B) of the AML/CTF Act. Each one captures a distinct category of work. If any of these show up on a file, that file is in scope.

1. Real estate transactions. Assisting in the planning or execution of a transaction to sell, buy or transfer real estate. Accountants often touch real estate transactions indirectly (structuring a trust to hold the property, advising on stamp duty, holding settlement funds). Where the practitioner is actively helping plan or execute the transaction, the work is captured.
2. Buying, selling or transferring a body corporate or legal arrangement. Business sales, share-sale or asset-sale transactions, and transfers of trusts or partnerships fall here.
3. Receiving, holding, controlling or managing client property. Trust-account work for transactional matters, holding deposits, and acting as the conduit for funds tied to a transaction are all in scope. Routine fee accounts on a tax return are not.
4. Equity or debt financing. Helping organise, plan or execute a capital raise, related-party loan, refinance, convertible note round or debt facility for a company or trust.
5. Selling or transferring a shelf company. Practitioners who keep a stock of clean Pty Ltd shells need a CDD file on every transferee, with beneficial ownership work on the buyer's structure.
6. Creating or restructuring a company or trust. The classic accountant set-up: SMSF establishment, family-trust formation, swapping a sole trader to a Pty Ltd, replacing a corporate trustee, splitting a discretionary trust, post-Div-7A restructures.
7. Acting in particular positions in a body corporate or legal arrangement. Acting as a nominee director, secretary or trustee for a client. Many small firms have a "house" trustee company; that company is in scope.
8. Arranging for someone to act in those positions. The second leg of items 7 to 8. Firms that source third-party nominees or trustees on behalf of clients are captured.
9. Providing a registered office or principal place of business address. Practitioners who use their own office address as the registered office for client companies are in scope, even where no other service is provided.

The full text and AUSTRAC's expanded commentary are on the Professional designated services page. AUSTRAC also publishes a short check-if-you're-regulated tool for firms that want a quick self-test.

Step 1: Enrol with AUSTRAC

Enrolment for newly regulated entities opens on 31 March 2026. Compliance obligations begin on 1 July 2026. The enrolment deadline for entities providing a new designated service is 29 July 2026. Enrolment is free and is done online through AUSTRAC Online.

You enrol the legal entity that provides the designated service. For a sole practitioner that is usually the practitioner's trading entity. For a multi-partner firm it is usually the principal trading company or partnership. If your firm uses multiple trading entities or a service-trust structure, work out which entity touches the designated service and enrol that one. AUSTRAC's reporting-group rules can simplify this where several related entities all touch the same service.

You will need: ABN/ACN details, business contact details, the AML/CTF Compliance Officer's name and role, and a description of the designated services you provide. Have the entity's structure chart on hand. A step-by-step walkthrough sits in our AUSTRAC enrolment guide.

One practical note: do not wait until the deadline week. AUSTRAC has indicated that the enrolment system will be busy through June and July 2026. Earlier enrolment also lets you slot the AML/CTF program work alongside enrolment rather than after it.

Step 2: Build Your AML/CTF Program

An AML/CTF program is a written document plus the systems that sit behind it. AUSTRAC's your AML/CTF program guidance describes the two halves: a governance side (Compliance Officer, board approval, training, independent evaluation, recordkeeping) and a risk-based systems side (your ML/TF risk assessment plus the CDD, sanctions, reporting and monitoring systems you actually run).

The program has to reflect your firm. A two-partner suburban practice with a stable client base does not need the same program as a mid-tier firm with corporate insolvency work and an SMSF book. AUSTRAC has published an Accountant Program Starter Kit for small low-complexity practices that includes a template program, a document library and "dealing with clients" examples.

The starter kit is a useful baseline. It is not a finished program. You still have to identify your firm's ML/TF risks, decide your risk appetite, set out CDD procedures that match your client mix, appoint the Compliance Officer, schedule training and arrange independent evaluation. Our standalone post on the AML/CTF program for an accounting firm walks through each part, and the AUSTRAC starter kits guide sets out what the kits do and do not cover.

Step 3: Customer Due Diligence Basics

CDD is the heart of the regime. Before you start providing a designated service, you identify your client, verify that identity, work out the client's beneficial owners where the client is a non-individual, and assess the ML/TF risk. AUSTRAC's customer due diligence guidance sets out the rules.

For accountants the typical client is not an individual. It is a Pty Ltd, a discretionary trust, a unit trust, an SMSF, a partnership or a layered structure. CDD on a Pty Ltd identifies the company, its directors, and the natural persons who ultimately own 25% or more or otherwise control the entity. CDD on a discretionary trust identifies the trust itself (using the trust deed), the trustee, the appointor or principal, and the named beneficiaries or classes of beneficiaries. CDD on an SMSF identifies the fund, the trustee (corporate or individual) and the members.

Higher-risk clients trigger Enhanced CDD. That includes source-of-funds work, source-of-wealth work, additional verification of beneficial owners, country-risk assessment, and senior management sign-off. Foreign clients, foreign PEPs, clients with opaque ownership and clients in higher-risk industries (cash-intensive businesses, virtual assets, certain remittance corridors) typically need ECDD.

The full CDD walk-through, with worked examples for companies, trusts and SMSFs, sits in our CDD for accountants on companies, trusts and SMSFs post.

Step 4: Ongoing Monitoring and SMRs

CDD is not a once-and-done event. You have an ongoing obligation to monitor your client base for changes in beneficial ownership, unusual activity, sanctions-list hits and changes in risk. AUSTRAC's ongoing customer due diligence guidance sets a risk-based standard: review schedules that match each client's risk rating, with event-based triggers on top.

The other ongoing obligation is suspicious matter reporting. If a reasonable person in your role would suspect that a transaction (or a proposed transaction) involves the proceeds of crime, terrorism financing, tax evasion or another offence, you lodge a Suspicious Matter Report with AUSTRAC. The deadline is 3 business days from forming the suspicion for general SMRs, and 24 hours for terrorism-financing matters. AUSTRAC's SMR guidance has the operational detail.

The hardest part of SMRs is the tipping-off rule under section 123 of the AML/CTF Act. You cannot tell the client (or anyone outside the narrow exceptions) that an SMR has been lodged or that one is being considered. Practical patterns for staying compliant sit in our SMRs and tipping-off for accountants post.

What Happens If You Do Not Comply

What to Do This Quarter

It is 15 May 2026 as this guide is published. There are roughly six weeks until the 1 July 2026 commencement and roughly 11 weeks until the 29 July 2026 enrolment deadline. A small practice can be ready inside that window if it works methodically.

1. Map your services. List every kind of file you take on. Tick which lines map to one or more of the nine professional designated services. If nothing maps, document the decision and revisit annually.
2. Appoint the AML/CTF Compliance Officer. In a small firm this is the principal. In a multi-partner firm it is a partner or senior manager at management level. Record the appointment in writing.
3. Decide which entity enrols. If the firm runs through multiple entities, work out which entity provides the designated service and which (if any) sit inside a reporting group.
4. Enrol with AUSTRAC. Open AUSTRAC Online, enrol the right entity, set up users, and lock in the Compliance Officer as primary contact.
5. Draft the program. Use the Accountant Program Starter Kit as a baseline. Tailor the risk assessment to your client mix. Approve the program in writing.
6. Stand up CDD. Decide your documents-by-entity-type list. Set risk ratings. Wire up sanctions and PEP screening. Run a test file through the workflow end-to-end before 1 July 2026.
7. Train the team. Every team member who can encounter a designated service needs role-relevant AML training. Record completion. Schedule the annual refresher.
8. Schedule the first independent evaluation. Diary the date and decide the scope. See our independent evaluation guide for the standard.

How AMLTranche Helps Accounting Firms

AMLTranche is purpose-built for Australian reporting entities including accountants, tax agents and bookkeepers. The platform pulls the whole program into one workflow: enrolment-ready data, an auto-generated AML/CTF program that mirrors the AUSTRAC Accountant Starter Kit structure, CDD workflows for Pty Ltd, discretionary trusts, unit trusts, SMSFs and partnerships, beneficial-ownership walk-throughs for layered structures, source-of-funds intake, DFAT sanctions and PEP screening with automatic re-screening, an SMR workflow with built-in tipping-off controls, and a 7-year tamper-proof audit log hosted in AWS Sydney.

Plans start at $59/mo + GST for sole practitioners. The full feature list and pricing sit on the AML software for accountants page.

Frequently Asked Questions

Do all Australian accountants need to comply with Tranche 2?

No. Only accountants who provide one of the nine professional designated services in table 6 of subsection 6(5B) of the AML/CTF Act are reporting entities. Routine tax return preparation, BAS and financial-statement work are not designated services on their own. The same practitioner becomes a reporting entity when their work touches one of the nine listed services (forming a company or trust, restructuring an entity, acting as a nominee, holding client money for a transaction, assisting with a real estate transfer, and so on).

When do accountants need to enrol with AUSTRAC?

Enrolment for newly regulated entities opens on 31 March 2026 through AUSTRAC Online. Compliance obligations begin on 1 July 2026. The enrolment deadline is 29 July 2026.

Does an SMSF accountant need to comply with Tranche 2?

Yes, where the work involves a designated service. Establishing an SMSF, restructuring it, helping a fund buy or transfer real estate, or holding fund money for a transaction are all captured. Routine fund administration on its own is not in scope, but where the practitioner also acts as a corporate trustee or holds client money, those services pull the practitioner into the regime.

What is the AML/CTF Compliance Officer role for an accounting firm?

Every reporting entity appoints an AML/CTF Compliance Officer at management level. In a small firm this is the principal. The role owns the program, CDD decisions, sanctions screening, SMR lodgement, training, recordkeeping and the response to AUSTRAC. The Compliance Officer is the firm's primary AUSTRAC contact and signs the annual independent evaluation request.

What are the penalties if an accounting firm does not comply?

AUSTRAC can apply to the Federal Court for civil penalty orders. The AML/CTF Act sets very large maximum penalty units for the most serious contraventions, and separately criminalises tipping off under section 123 (up to 2 years imprisonment or 120 penalty units, or both). Professional bodies may also act. See AUSTRAC's consequences of not complying page.

Disclaimer: This article provides general information about AML/CTF Tranche 2 obligations for accountants and does not constitute legal advice. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. AMLTranche helps streamline AML/CTF compliance workflows alongside your professional advisers.