How long do I have to transition from ACIP to new CDD requirements?

The transitional period runs from 31 March 2026 to 31 March 2029. However, this only applies if you were enrolled as a reporting entity on 30 March 2026. Newly regulated businesses like most real estate agents must comply with new initial CDD obligations from 1 July 2026.

When must I notify AUSTRAC of my AML/CTF compliance officer?

If you were enrolled on 30 March 2026, you must notify AUSTRAC by 30 May 2026. If you are a newly regulated business, you must notify by the later of 14 days after enrolment or 29 July 2026.

When is my first independent evaluation due?

For newly regulated businesses, the deadline depends on the last two digits of your AUSTRAC Account Number (AAN): both odd = 30 June 2029, second-last odd/last even = 31 December 2029, both even = 30 June 2030, second-last even/last odd = 31 December 2030.

Do the transitional rules apply to newly regulated property professionals?

The ACIP-to-CDD transitional period does NOT apply to most property professionals since they are newly regulated and weren't enrolled before 30 March 2026. However, the extended compliance officer notification deadline and staggered independent evaluation timelines do apply.

AUSTRAC AML/CTF Transitional Rules 2026: What Property Professionals Need to Know

Key Takeaways

Existing reporting entities enrolled before 30 March 2026 can continue using ACIP instead of new CDD until 31 March 2029.
Newly regulated property professionals (most of you) must comply with full initial CDD from 1 July 2026 — no transitional relief.
Compliance officer notification deadline: 30 May 2026 for existing entities, or the later of 14 days after enrolment / 29 July 2026 for new entities.
First independent evaluation deadline depends on your AUSTRAC Account Number (AAN) — between June 2029 and December 2030.
New ongoing CDD obligations apply to all reporting entities from 31 March 2026, regardless of transitional arrangements.

In this guide

What are the transitional rules? Transitional period for customer due diligence Extended deadline for compliance officer notification Staggered independent evaluation timelines What this means for property professionals Key dates summary What you should do right now

What Are the AUSTRAC Transitional Rules?

On 30 March 2026, AUSTRAC published the Anti-Money Laundering and Counter-Terrorism Financing Transitional Rules 2026. These rules support a smooth implementation of the AML/CTF reforms by giving some reporting entities more time to update their systems, processes, and AML/CTF programs.

Different transitional arrangements apply depending on two factors: your enrolment date and the designated services you provide. This is important because it means the transitional rules don't apply equally to everyone. Some businesses get significant extra time; others — including most property professionals — get very little.

The transitional rules cover several areas including CDD transitions, compliance officer notification, independent evaluations, international value transfer reporting, and virtual asset services. For property professionals, the three most relevant sections are the CDD transition, compliance officer deadline, and evaluation timeline.

Transitional Period for Initial Customer Due Diligence

This is the biggest transitional concession, and it's critical to understand whether it applies to you. Under Part 3 of the transitional rules, certain reporting entities can continue using applicable customer identification procedures (ACIP) instead of the new initial customer due diligence (CDD) obligations for a limited time.

Who qualifies for the ACIP transitional period?

You can use this transitional arrangement only if both of the following apply:

You were enrolled as a reporting entity on 30 March 2026
You maintain AML/CTF policies that require you to use ACIP that complied with the AML/CTF Rules in force on that date

The transitional period runs from 31 March 2026 to 31 March 2029 — giving qualifying entities up to three years to transition.

What you must do to rely on this rule

If you qualify, you must have transitional policies in place by 1 July 2026 that:

List the classes of customers you will apply ACIP to
State the date when you'll stop applying ACIP to each class
Appropriately manage and mitigate your ML/TF risks
Are appropriate to the nature, size, and complexity of your business

You can define customer classes however makes sense for your business — by legal form (individuals, companies, trusts), geographic location, type of designated service, or business line. Each customer class must be subject to either ACIP or the new initial CDD framework at any given time, not both.

⚠️ Critical: Ongoing CDD still applies immediately

Even if you qualify for the ACIP transitional period, you must comply with the new ongoing CDD obligations from 31 March 2026. The transitional arrangement applies only to initial CDD. You also cannot use the new deemed compliance or delayed CDD provisions until you have fully transitioned to the new initial CDD framework. See AUSTRAC's full guidance for details.

How AUSTRAC expects you to manage the transition

AUSTRAC expects a structured transition. While they recognise that short operational overlap may occur as you update systems, your implementation plan must clearly explain:

Which customer classes you will transition and when
How you will minimise and control overlap between ACIP and the new framework
How both ACIP and initial CDD arrangements will continue to manage ML/TF risks

Learn more about AUSTRAC's regulatory expectations and priorities.

Extended Deadline for Compliance Officer Notification

Under Part 8 of the transitional rules, AUSTRAC has extended the time you have to notify them of your AML/CTF compliance officer. The deadlines differ based on when you enrolled:

Compliance officer notification deadlines

Existing entities If enrolled on 30 March 2026, you must notify AUSTRAC of your compliance officer by 30 May 2026.

Newly regulated Must notify by the later of: 14 days after your enrolment with AUSTRAC, or 29 July 2026.

Example If you enrol on 29 July 2026, you would have until 12 August 2026 to notify AUSTRAC of your compliance officer.

After the transitional period ends, the standard 14-day notification rule applies going forward. The compliance officer is the person responsible for day-to-day AML/CTF management — typically the principal, office manager, or a senior agent.

Staggered Independent Evaluation Timelines

The reforms replace the old independent reviews of Part A of your AML/CTF program with independent evaluations of your entire AML/CTF program. Under Part 7 of the transitional rules, AUSTRAC has staggered the deadlines for first evaluations to avoid overwhelming the market.

For newly regulated businesses (most property professionals)

Your first independent evaluation deadline depends on the last two digits of your AUSTRAC Account Number (AAN), which you receive when you enrol:

Independent evaluation deadlines by AAN

1 Both digits odd (e.g., AAN ending in 13, 57, 91) — by 30 June 2029

2 Second-last odd, last even (e.g., AAN ending in 12, 54, 90) — by 31 December 2029

3 Both digits even (e.g., AAN ending in 24, 68, 02) — by 30 June 2030

4 Second-last even, last odd (e.g., AAN ending in 21, 63, 07) — by 31 December 2030

For existing regulated entities

If you were enrolled on 30 March 2026 and have already had at least one independent review, you must conduct your first independent evaluation by the later of:

4 years after your most recent independent review, or
31 March 2027

Update your AML/CTF program so your evaluation schedule aligns with the deadline you've identified. Learn more about conducting an independent evaluation.

What This Means for Property Professionals Specifically

Here's the bottom line for real estate agents, conveyancers, and property developers:

💡 The ACIP transitional period does NOT apply to most property professionals

The CDD transitional arrangement requires you to have been enrolled as a reporting entity on 30 March 2026. Since real estate agents, conveyancers, and property developers are newly regulated under Tranche 2, the vast majority were not enrolled before this date. This means you must comply with full initial CDD obligations from 1 July 2026 — there is no three-year grace period for you.

What does apply to you

Extended compliance officer notification: You have until the later of 14 days after enrolment or 29 July 2026 to notify AUSTRAC of your compliance officer.
Staggered independent evaluation: Your first evaluation is due between June 2029 and December 2030 depending on your AAN digits — giving you 3–4 years to prepare.
Full CDD from day one: You must have customer due diligence workflows in place before 1 July 2026 for individuals, companies, trusts, SMSFs, and partnerships.
AML/CTF program required: Your written, risk-based AML/CTF program must be approved and operational by 1 July 2026.

Use AUSTRAC's eligibility checker to confirm whether your business is affected.

Key Dates Summary

Complete transitional rules timeline

31 Mar 2026 Reforms commence. Enrolment opens. Ongoing CDD obligations begin for all reporting entities. ACIP transitional period starts for qualifying existing entities.

30 May 2026 Compliance officer deadline (existing entities). Must notify AUSTRAC of your AML/CTF compliance officer.

1 Jul 2026 Full obligations commence for newly regulated businesses. AML/CTF program, initial CDD, sanctions screening, reporting, record-keeping, and staff training must all be in place.

29 Jul 2026 Enrolment deadline. All newly regulated businesses must have enrolled with AUSTRAC.

12 Aug 2026 Latest compliance officer deadline (newly regulated). If you enrolled on the last day (29 July), you have until this date.

Jun 2029 – Dec 2030 First independent evaluation due. Staggered based on last 2 digits of your AUSTRAC Account Number.

31 Mar 2029 ACIP transitional period ends. All reporting entities must use the new initial CDD framework from this date.

What Should You Do Right Now?

The transitional rules give you some breathing room on evaluations, but zero extra time on the core obligations. If you're a newly regulated property professional, here's your action plan:

Your immediate action items

✓ Complete your ML/TF risk assessment now. Don't wait for enrolment to open. You can generate a risk assessment for free with AMLTranche.

✓ Draft your AML/CTF program. It must be written, risk-based, and approved by your principal or board before 1 July 2026.

✓ Set up CDD workflows. You need processes for individuals, companies, trusts, SMSFs, and partnerships from day one. No transitional period applies.

✓ Configure sanctions and PEP screening. DFAT Consolidated List screening must be operational from 1 July 2026.

✓ Appoint your compliance officer. Decide who this will be now — you'll need to notify AUSTRAC within 14 days of enrolment.

✓ Train your staff. All team members need role-specific AML/CTF training before obligations go live.

✓ Enrol with AUSTRAC. Enrolment opens 31 March 2026 and must be completed by 29 July 2026.

Read the full AUSTRAC transitional rules guidance for complete details on all transitional arrangements, including those for financial advisers, virtual asset service providers, and international value transfer reporting.

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Source: This article is based on AUSTRAC's official guidance: AML/CTF Transitional Rules 2026, last updated 30 March 2026.

Disclaimer: This article provides general information about the AUSTRAC AML/CTF transitional rules and does not constitute legal advice. While we've referenced official AUSTRAC guidance and the AML/CTF Act, you should confirm your specific obligations with AUSTRAC or a qualified legal adviser. AMLTranche helps streamline your compliance workflows alongside your professional advisers.