When is the enrolment deadline?

Enrol within 28 days of first providing a designated service (s 51B). For a business already providing the service on 1 July 2026, that was 29 July 2026.

Do bookkeepers need to enrol with AUSTRAC?

The AML/CTF Tranche 2 test for bookkeepers, from the designated-service tables in section 6 of the AML/CTF Act and AUSTRAC's sector guidance.

Short answer: Only if you provide a designated service

A bookkeeper is not a reporting entity just because it keeps books. Enrolment is required only if the practice provides a designated service in table 6 of section 6 of the AML/CTF Act, for example managing client money for a transaction, helping a client buy or sell a business, or creating a company or trust. Routine payments made for a client, where the practice provides no other designated service, are carved out of item 3.

The designated services that catch bookkeepers

AML/CTF Act reference	Service	Customer for due diligence
s 6 table 6 items 2–4	Assisting with the sale or purchase of a body corporate or legal arrangement; holding, controlling or managing client money or property for a transaction; equity or debt financing	The person assisted
s 6 table 6 items 5–9	Selling shelf companies; creating or restructuring companies and trusts; acting as, or arranging for someone to act as, a director, secretary, trustee, partner or corporate power of attorney; acting as a nominee shareholder; providing a registered office or principal place of business address	Varies: for company creation, the proposed beneficial owners and directors; for an express trust, the trustee, settlor and beneficiaries; for nominee and officer services, the nominator
s 6 table 6 item 1	Assisting a person to plan or execute a real estate transaction (not under a court order)	The person assisted

AUSTRAC's test for table 6 is whether the provider directly advances the transaction. Advice that only influences a transaction is not caught; the service starts when the provider acts on instructions and a transaction exists (for a private sale, once a price is agreed).

Carve-outs and exemptions to check

Payments for the bookkeeper's own fees are excluded from item 3 (s 6(5C)–(5D)).
Incidental payments where the practice provides no other designated service, such as a bookkeeper's routine payments for a client, are excluded from item 3.
Payments to or from government, courts or licensed insurers are excluded from item 3.

Enrolment deadlines and what follows

Enrol within 28 days of first providing a designated service (s 51B). For a business already providing the service on 1 July 2026, that was 29 July 2026.
Each day a designated service is provided while unenrolled can be a separate contravention (s 51B(2C)).
Notify AUSTRAC of changes to enrolment details within 14 days (s 51F, Rules r 3-9), including adding a new designated service.
Designate an AML/CTF compliance officer within 28 days of first providing a designated service (s 26K) and notify AUSTRAC within 14 days (s 26M). For newly regulated businesses the transitional deadline was the later of 29 July 2026 or 14 days after enrolling (Transitional Rules s 19).

Enrolment is the first step, not the last

An enrolled business must also have an AML/CTF program before it provides a designated service: an ML/TF risk assessment plus AML/CTF policies covering customer due diligence, reporting (suspicious matters within 3 business days, threshold transactions of $10,000 or more in cash within 10 business days), record keeping, personnel due diligence, training and governance. The first annual compliance report covers 1 July 2026 to 30 June 2027 and is due by 30 September 2027.

AUSTRAC's accountant starter kit is written for small accounting practices. Before relying on it, test the practice against the kit's "who the starter kit is for" criteria, including the 15-personnel limit.

AUSTRAC had 13,780 enrolments in this category as at 17 September 2026. AUSTRAC reports accounting and professional services as one enrolment category; bookkeepers are not counted separately.

If you should be enrolled and are not

AUSTRAC can issue an infringement notice of $21,840 for a company or $4,368 for an individual per contravention (60 or 12 penalty units at $364), or seek a civil penalty of up to $36.4M (body corporate) or $7.28M (individual) per contravention. Since 28 August 2026 AUSTRAC has been issuing section 167 notices to businesses that appear to provide designated services without enrolling.

Check your AML/CTF programUpload the AML/CTF program you already have and get a gap score against the Tranche 2 requirements of the Act and Rules. Personal information is removed before analysis.Run the compliance journeyAnswer a short questionnaire about your business and get the obligations that apply to you, with the reason each one applies.

Questions

Do bookkeepers need to enrol with AUSTRAC?: Only if you provide a designated service. A bookkeeper is not a reporting entity just because it keeps books. Enrolment is required only if the practice provides a designated service in table 6 of section 6 of the AML/CTF Act, for example managing client money for a transaction, helping a client buy or sell a business, or creating a company or trust. Routine payments made for a client, where the practice provides no other designated service, are carved out of item 3.
When is the enrolment deadline?: Enrol within 28 days of first providing a designated service (s 51B). For a business already providing the service on 1 July 2026, that was 29 July 2026.
Is there a starter kit for bookkeepers?: AUSTRAC's accountant starter kit is written for small accounting practices. Before relying on it, test the practice against the kit's "who the starter kit is for" criteria, including the 15-personnel limit.

Sources

Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.