Banks & ADIs compliance obligations for a trading trust
Computed by the Rules Mate applicability engine for a trading trust in banks & adis with 6–19 employees, turnover $1M–$3M, selling to consumers and small businesses.
Short answer: 65 obligations
65 Commonwealth obligations apply to a trading trust in banks & adis with 6–19 employees, turnover $1M–$3M (30 critical), plus 12 to check. Risk rating: high. Licensed or supervised regime: AML/CTF reporting entity, credit provider, APRA-regulated. These carry licence conditions, regulator audit and per-contravention civil penalties.
What the structure changes
Compared with a Pty Ltd company of the same size in banks & adis, a trading trust picks up 1 Commonwealth obligation and drops 9.
- Does not apply: Apply for a Director Identification Number (Director ID)
- Does not apply: Comply with directors' general law and statutory duties
- Does not apply: Prevent insolvent trading (s 588G)
- Does not apply: Pay company PAYG/GST/SG or face Director Penalty Notice (DPN)
- Does not apply: Lodge the ASIC annual company statement and review fee
- Does not apply: Determine large proprietary company status annually
- Does not apply: Pay ASIC fees + lodge prescribed forms
- Does not apply: Discharge of directors' duties — practical evidence
- Does not apply: Beneficial ownership transparency (Tranche 3 — under consultation)
Duties that come with being a trading trust
Critical Commonwealth obligations on this profile
- Enrol with AUSTRAC as a reporting entity (Authorised deposit-taking institution — AML/CTF reporting entity)
- Maintain a written AML/CTF program (Authorised deposit-taking institution — AML/CTF reporting entity)
- Customer due diligence (KYC) on every customer (Authorised deposit-taking institution — AML/CTF reporting entity)
- Suspicious matter, threshold, and IFTI reporting to AUSTRAC (Authorised deposit-taking institution — AML/CTF reporting entity)
- Notifiable Data Breach (NDB) scheme (AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A)))
- Pay superannuation on every payday (Payday Super) (You have employees (6–19))
- Pay employees in accordance with the applicable modern award (You have employees (6–19))
- Manage psychosocial hazards at work (You have employees (6–19))
Check whether these apply
- Mortgage broker best interests duty: only if you are a mortgage broker
- Small Amount Credit Contract + Consumer Lease caps (post-SACC reforms): only if you provide small amount credit contracts or consumer leases
- Lodge an FBT return and pay FBT by 21 May: only if you provide fringe benefits (cars, entertainment, loans) to employees
- Wash outbound marketing lists against the Do Not Call Register: only if you make outbound telemarketing calls
- Influencer + ad disclosure under ACL + AANA Code: only if you advertise to consumers or engage influencers
- Pre-2025 ban on unsolicited credit limit increase invitations: only if you issue credit cards
- Pay redundancy under NES (s 119 FW Act): only if you have 15 or more employees (FW Act s 121 small business exemption)
- Track eligibility for the electric car FBT exemption: only if you provide electric vehicles to employees
State and territory law
This page counts Commonwealth obligations only. Payroll tax, workplace safety, licensing and other state duties depend on where the business operates; the industry's state pages list them.
Other structures and industries
Questions
- What compliance obligations apply to a trading trust in banks & adis?
- 65 Commonwealth obligations apply to a trading trust in banks & adis with 6–19 employees, turnover $1M–$3M (30 critical), plus 12 to check. Risk rating: high. Licensed or supervised regime: AML/CTF reporting entity, credit provider, APRA-regulated. These carry licence conditions, regulator audit and per-contravention civil penalties.
- What changes compared with a Pty Ltd company of the same size?
- A trading trust picks up 1 obligations and drops 9, including Make trustee resolutions for trust distributions by 30 June.
Related
- Banks & ADIs: all obligations
- Compliance obligations by structure
- Compliance obligations by industry, state and size
- Enrol with AUSTRAC as a reporting entity: does it apply to banks & adis?
- Maintain a written AML/CTF program: does it apply to banks & adis?
- Customer due diligence (KYC) on every customer: does it apply to banks & adis?
- Suspicious matter, threshold, and IFTI reporting to AUSTRAC: does it apply to banks & adis?
Sources
- Make trustee resolutions for trust distributions by 30 June
- Enrol with AUSTRAC as a reporting entity
- Customer due diligence (KYC) on every customer
- Suspicious matter, threshold, and IFTI reporting to AUSTRAC
- Notifiable Data Breach (NDB) scheme
- Pay superannuation on every payday (Payday Super)
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.