Tranche 2 AML reforms explained
Overview. From 1 July 2026, Australia's anti-money-laundering and counter-terrorism-financing (AML/CTF) rules were extended to around 90,000 new businesses, including accountants, lawyers, conveyancers, real estate professionals, and dealers in precious metals and stones. These "Tranche 2" entities must now identify and verify their customers, assess and monitor money-laundering risk, and keep records. The AUSTRAC enrolment deadline is 29 July 2026.
This article is general information, not legal advice. Always confirm your specific obligations against the live AUSTRAC guidance. IdentityCheck helps you meet several of these obligations; it does not by itself make your firm compliant.
Download the Tranche 2 Quick Start Guide (PDF)
What changed, and when
The reforms flow from the AML/CTF Amendment Act 2024. The dates that matter for a newly captured firm:
| Milestone | Date | Status |
|---|---|---|
| Reform framework commences (programs, CDD, new high-risk services) | 31 March 2026 | In force |
| AUSTRAC enrolment opens for Tranche 2 entities | 31 March 2026 | Open |
| Tranche 2 obligations commence | 1 July 2026 | In force now |
| Enrolment deadline for Tranche 2 entities | 29 July 2026 | Upcoming |
| Compliance-officer notification deadline | later of 29 July 2026, or 14 days after enrolment | Upcoming |
The single most common error in third-party articles is a "31 March 2026 enrolment deadline". That is wrong: 31 March was the date enrolment opened. The deadline is 29 July 2026. See Key AML dates and the enrolment deadline.
Who is now captured
The reform regulates businesses that provide specific "designated services", not entire professions. A firm is captured only for the designated services it actually provides.
- Real estate professionals: agents, buyer's agents and property developers brokering sales, purchases or transfers of real estate.
- Professional services: lawyers, conveyancers, accountants, and trust and company service providers, where they help buy, sell or transfer real estate; help buy or sell bodies corporate or legal arrangements; hold or manage client money; sell shelf companies; create or restructure companies or trusts; or act as (or arrange) a nominee director, shareholder or registered-office provider.
- Dealers in precious metals, stones and products: where payment involves physical currency or virtual assets totalling AUD $10,000 or more.
- Plus expanded virtual-asset services.
Common accounting work such as general tax advice, preparing tax returns, audit and bookkeeping does not, on its own, make a firm a reporting entity. A service is captured only when the professional's assistance directly advances the relevant transaction. To check your own situation, see Designated services under Tranche 2: am I in scope?.
The seven obligations
- Enrol with AUSTRAC.
- Maintain an AML/CTF program: a money-laundering, terrorism-financing and proliferation-financing risk assessment, plus policies, with senior-management approval, an appointed compliance officer, and independent evaluation at least every three years.
- Initial customer due diligence (CDD): identify and verify the customer (and relevant beneficial owners) before providing a designated service.
- Ongoing CDD and monitoring throughout the customer relationship.
- Enhanced CDD (EDD) where money-laundering risk is high.
- Reporting: suspicious matter reports (SMRs) and threshold transaction reports (TTRs).
- Record keeping.
What about existing clients?
There is transitional relief. You are not required to perform initial or ongoing CDD on customers you had before 1 July 2026 until a suspicious matter report is required, or a significant change makes that customer's risk medium or high.
How IdentityCheck helps
IdentityCheck is built to help with the customer-facing obligations: initial CDD (identity verification and information collection), the customer risk assessment, enhanced due diligence, ongoing monitoring, and the record keeping and audit trail behind all of it. It does not enrol you, write your program, or lodge your reports. See How IdentityCheck maps to your AML obligations.
Official sources
AUSTRAC is the authority on your obligations. Useful starting points: AUSTRAC's "Preparing for the changes if you're newly regulated" hub, its "New industries and services to be regulated" scope guidance, the sector-specific AML/CTF program starter kits, and AUSTRAC's "check if you may be regulated" self-assessment tool.