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 buyer's agents need to enrol with AUSTRAC?

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

Short answer: Yes

A buyer's agent brokers the purchase of real estate, which is a designated service under table 5, item 1 of section 6 of the AML/CTF Act. The obligations are the same as for a selling agent: enrol within 28 days of first providing the service, have an AML/CTF program in place before providing it, and treat both the buyer and the seller as customers for customer due diligence.

The designated services that catch buyer's agents

AML/CTF Act reference	Service	Customer for due diligence
s 6 table 5 item 1	Brokering the sale, purchase or transfer of real estate	Both the buyer and the seller

Real estate customer due diligence can be delayed: the deadline is the earlier of 28 days after exchange or 3 days before settlement (Rules r 6-32(4)).

Carve-outs and exemptions to check

Leases of 30 years or less, easements, mortgagee interests and standalone licences to occupy are outside the definition of real estate.
Advice that does not broker a sale, purchase or transfer is not the table 5 service.

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 real estate starter kit covers brokering. A buyer's agency should test itself against the kit's suitability criteria, including that it brokers only and is not a developer.

AUSTRAC had 18,350 enrolments in this category as at 17 September 2026. AUSTRAC reports real estate as one enrolment category; buyer's agents 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 buyer's agents need to enrol with AUSTRAC?: Yes. A buyer's agent brokers the purchase of real estate, which is a designated service under table 5, item 1 of section 6 of the AML/CTF Act. The obligations are the same as for a selling agent: enrol within 28 days of first providing the service, have an AML/CTF program in place before providing it, and treat both the buyer and the seller as customers for customer due diligence.
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 buyer's agents?: AUSTRAC's real estate starter kit covers brokering. A buyer's agency should test itself against the kit's suitability criteria, including that it brokers only and is not a developer.

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.