Do real estate agents need to enrol with AUSTRAC?
The AML/CTF Tranche 2 test for real estate agents, from the designated-service tables in section 6 of the AML/CTF Act and AUSTRAC's sector guidance.
Short answer: Yes
Brokering the sale, purchase or transfer of real estate is a designated service under table 5, item 1 of section 6 of the AML/CTF Act. A sales agency must enrol within 28 days of first providing that service, and both the buyer and the seller are its customers for customer due diligence.
The designated services that catch real estate 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 |
| s 6 table 5 item 2 | Selling or transferring real estate in the course of a business where no independent agent is involved (for example a developer selling direct) | The buyer |
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
- Property management of rental income through a trust account is excluded by the Rules, so a rent-roll-only agency is not caught by that activity.
- Leases of 30 years or less, easements, mortgagee interests and standalone licences to occupy are outside the definition of real estate.
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 publishes a real estate starter kit for agencies that broker sales only (not developers) and meet the other suitability criteria.
AUSTRAC had 18,350 enrolments in this category as at 17 September 2026.
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.
Questions
- Do real estate agents need to enrol with AUSTRAC?
- Yes. Brokering the sale, purchase or transfer of real estate is a designated service under table 5, item 1 of section 6 of the AML/CTF Act. A sales agency must enrol within 28 days of first providing that service, and both the buyer and the seller are its 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 real estate agents?
- AUSTRAC publishes a real estate starter kit for agencies that broker sales only (not developers) and meet the other suitability criteria.
Related
- AML/CTF Tranche 2 guides
- Who must comply with AUSTRAC enrolment
- Who must comply with the AML/CTF program obligation
- Does the AML/CTF program apply to real estate agents?
- Do bookkeepers need to enrol with AUSTRAC?
- Do accountants need to enrol with AUSTRAC?
- Do conveyancers need to enrol with AUSTRAC?
- Do buyer's agents need to enrol with AUSTRAC?
- Do lawyers need to enrol with AUSTRAC?
- Do trust and company service providers need to enrol with AUSTRAC?
- Do jewellers need to enrol with AUSTRAC?
- Received an AUSTRAC section 167 notice?
Sources
- AUSTRAC: Real estate designated services (table 5)
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (compilation in force 1 Jul 2026)
- AUSTRAC: Enrol with us
- AUSTRAC: Program starter kits
- AUSTRAC: Consequences of not complying
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.