Key Takeaways

In this article

Days remaining Complete Tranche 2 timeline What to do before March 31 April to June: Build your program July 1: Day one obligations After July: Ongoing deadlines Transition period Frequently asked questions

The Clock Is Ticking

Until AUSTRAC Enrolment Opens
27
Days
31 March 2026
Until Obligations Commence
119
Days
1 July 2026

These aren't arbitrary dates. Missing them carries penalties of up to $33 million per breach under the AML/CTF Act, criminal charges, and even imprisonment. Every real estate agent, conveyancer, and property developer in Australia is on this same clock.

Complete Tranche 2 Timeline

August 2025
AUSTRAC releases AML/CTF Rules for Tranche 2
The final rules were published, formally bringing real estate agents, conveyancers, property developers, lawyers, and accountants into the AML/CTF regime.
December 2025
AML/CTF Act amendments receive Royal Assent
The legislation passed Parliament and became law, confirming the July 2026 commencement date for all Tranche 2 entities.
February 2026
AUSTRAC releases program starter kits
Sector-specific guidance published for real estate agents, including the real estate program starter kit with templates and checklists to help businesses build their AML/CTF programs.
31 March 2026
AUSTRAC enrolment opens
The enrolment portal opens for all Tranche 2 entities. You can register your business as a reporting entity from this date. Don't wait until the last minute—enrol early to avoid technical issues and delays.
April – June 2026
Preparation window
Your 3-month window to finalise your AML/CTF program, appoint a compliance officer, train staff, set up CDD processes, and configure sanctions screening. This is the most important period.
1 July 2026
AML/CTF obligations commence
From this date, you must conduct customer due diligence on all new clients, screen against DFAT sanctions lists, report suspicious matters, and maintain records. Providing designated services without compliance is a criminal offence.
29 July 2026
Hard deadline: AUSTRAC enrolment
If you were providing designated services on 1 July, you must be enrolled by this date (28 days after commencement). Providing services without enrolling is a criminal offence under the AML/CTF Act.
29 July 2026
Compliance Officer notification deadline
You must notify AUSTRAC of the identity of your AML/CTF Compliance Officer by this date. The compliance officer must be at management level.

What to Do Before March 31

Enrolment opens in less than 4 weeks. Use this time to get prepared so you can enrol immediately when the portal opens.

Before March 31 checklist

1 Confirm you're affected. Check if your business provides "designated services" under the reforms. Use AUSTRAC's decision tool to find out.
2 Gather your business details. You'll need your ABN, business structure, list of designated services you provide, and details of your business locations.
3 Choose your AML/CTF Compliance Officer. This must be someone at management level. Decide who this will be now so you can include them in the enrolment.
4 Start your risk assessment. Identify your ML/TF risks based on your services, clients, and geographic exposure. This informs everything else in your program.
5 Read the AUSTRAC enrolment guide so you know exactly what the form asks and can complete it quickly on March 31.

April to June: Build Your Compliance Program

This is your critical 3-month preparation window. Everything you build during this period must be operational by July 1.

April – June action plan

1 Enrol with AUSTRAC as soon as the portal opens on March 31. Don't wait until June.
2 Develop your AML/CTF program. Document your policies, procedures, and controls. It must be approved by a senior manager and cover all six obligations.
3 Set up customer due diligence (CDD) processes. Define how you'll verify client identities, check beneficial ownership, and conduct ongoing monitoring.
4 Configure sanctions screening. Set up DFAT sanctions list and PEP screening for all clients. This must run before you provide any designated service.
5 Train your staff. Everyone involved in providing designated services must understand their AML/CTF obligations, how to spot red flags, and how to escalate suspicious matters.
6 Set up reporting processes. Know how to file a Suspicious Matter Report (SMR) and have your reporting channels ready before July 1.
7 Establish record-keeping. All CDD records, transaction records, and training records must be kept for at least 7 years. Set up secure storage now.

July 1: What Happens on Day One

From 1 July 2026, every time you provide a designated service, you must:

Day one obligations

! Verify every new client's identity before providing a designated service. No exceptions.
! Screen all clients against DFAT sanctions lists and check for Politically Exposed Persons (PEPs).
! Identify beneficial owners for companies, trusts, and other complex structures.
! Report suspicious matters within 24 hours if terrorism financing is suspected, or within 3 business days for other suspicious matters.
! Keep detailed records of all CDD, transactions, and compliance activities for 7 years minimum.

If you haven't prepared before this date, you cannot legally provide designated services until your compliance program is in place. For a real estate agency, that means you cannot list, sell, or manage property transactions.

After July: Ongoing Deadlines

Ongoing reporting deadlines from 1 July 2026

Suspicious Matter Reports (SMRs): Within 24 hours for terrorism financing, 3 business days for other suspicious matters.

Threshold Transaction Reports: Cash transactions of $10,000 or more must be reported within 10 business days.

International Funds Transfer Instructions: Must be reported within 10 business days.

Annual compliance report: Must be submitted to AUSTRAC annually.

Independent review: Your AML/CTF program must be independently reviewed at least once every 3 years. For new Tranche 2 entities, the first review is due by 1 July 2029.

Transition Period: What Flexibility Do You Have?

AUSTRAC has built in some transitional provisions, but they're limited:

In other words, if you're a real estate agency, conveyancer, or property developer, there is no soft launch. You must be fully compliant from day one. Start with AUSTRAC's Before You Start guidance to understand what is required.

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Frequently Asked Questions

When does AUSTRAC enrolment open for Tranche 2?

AUSTRAC enrolment for Tranche 2 entities opens on 31 March 2026. This applies to real estate agents, conveyancers, property developers, lawyers, and accountants.

What is the deadline to enrol with AUSTRAC?

If you are providing designated services on 1 July 2026, you must be enrolled by 29 July 2026 (28 days after commencement). If you start providing designated services after 1 July, you must enrol within 28 days of first providing the service.

When do AML/CTF obligations start for real estate agents?

AML/CTF obligations commence on 1 July 2026. From this date you must have your AML/CTF program in place, a compliance officer appointed, staff trained, and be conducting customer due diligence and reporting suspicious matters.

Is there a transition period for Tranche 2 entities?

For new Tranche 2 entities, no—you must be fully compliant from 1 July 2026. Existing reporting entities (already regulated under Tranche 1) have until 30 March 2029 to transition their customer identification procedures to the new CDD requirements.

Last updated: 4 March 2026. This article is for general information only and does not constitute legal advice. Dates are based on published AUSTRAC guidance and may be subject to change. For advice specific to your circumstances, consult a qualified legal professional.