Real estate agents compliance obligations in Australian Capital Territory: 100–499 employees, turnover $100M–$1B
Computed by the Rules Mate applicability engine for a Pty Ltd company with 100–499 employees, turnover $100M–$1B, in real estate agents, operating in Australian Capital Territory and selling to consumers and small businesses.
Short answer: 72 obligations
72 obligations apply (26 critical) across 32 regulators, plus 12 to check. Risk rating: high. Licensed or supervised regime: AML/CTF reporting entity. These carry licence conditions, regulator audit and per-contravention civil penalties.
Turnover $100M–$1B instead of $10M–$100M: what changes
Compared with a Pty Ltd company with 100–499 employees, turnover $10M–$100M in Australian Capital Territory, 10 obligations apply that did not.
- Applies: AASB S2 Scope 3 emissions + assurance phase-in
- Applies: Lodge mandatory climate-related financial disclosures (ASRS S2)
- Applies: Publish an annual Modern Slavery Statement
- Applies: Maintain auditor / financial reporting (Chapter 2M)
- Applies: Comply with corporate whistleblower protections (Part 9.4AAA Corporations Act)
- Applies: Lodge Payment Times Reports (large business)
- Applies: ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027
- Applies: Scope 3 emissions disclosure (AASB S2 + voluntary)
- Applies: Modern Slavery Statement (Cwlth)
- Applies: Climate scenario analysis (AASB S2)
Australian Capital Territory law that applies
4 Australian Capital Territory obligations apply on these facts:
| Obligation | Why it applies |
|---|---|
| PCBU primary duty of care (ACT WHS Act s 19) | Every business is a PCBU — the primary duty of care applies whether or not you employ anyone · ACT law |
| Industrial manslaughter offence (ACT WHS Act s 34A) | Applies to every PCBU and its officers — a death caused by reckless or negligent breach of a WHS duty is a crime · ACT law |
| Pay ACT payroll tax when threshold met | 100–499 employees — wages far exceed the ACT payroll tax threshold of $1.75M |
| Comply with Workplace Privacy Act 2011 (ACT) | You have employees (100–499) · ACT law |
Payroll tax in Australian Capital Territory (FY2026-27)
ACT: 6.75% on Australian wages above the $1.75 million tax-free threshold (FY2026-27). On these facts it applies: 100–499 employees — wages far exceed the ACT payroll tax threshold of $1.75M.
- How the threshold works
- Flat tax-free threshold, apportioned by days employed and the ACT share of Australia-wide wages.
- Returns
- Monthly by the 7th of the following month; annual reconciliation by 28 July
- Administered by
- ACT Revenue Office
Australian Capital Territory regulators
Where the obligations sit
| Area | Obligations |
|---|---|
| Privacy | 9 |
| Aml ctf | 8 |
| Workplace | 8 |
| Tax | 7 |
| Climate | 5 |
| Directors | 4 |
| Whs | 4 |
| Super | 2 |
| Migration | 2 |
| Corporations | 2 |
Critical obligations on this profile
- Enrol with AUSTRAC as a reporting entity (Tranche 2 industry (Real estate agents) — AML/CTF reporting entity from 1 July 2026)
- Maintain a written AML/CTF program (Tranche 2 industry (Real estate agents) — AML/CTF reporting entity from 1 July 2026)
- Customer due diligence (KYC) on every customer (Tranche 2 industry (Real estate agents) — AML/CTF reporting entity from 1 July 2026)
- Suspicious matter, threshold, and IFTI reporting to AUSTRAC (Tranche 2 industry (Real estate agents) — AML/CTF reporting entity from 1 July 2026)
- Notifiable Data Breach (NDB) scheme (Annual turnover over $3M — an APP entity under the Privacy Act (s 6D))
- Apply for a Director Identification Number (Director ID) (Incorporated company (Corporations Act))
- Comply with directors' general law and statutory duties (Incorporated company (Corporations Act))
- Prevent insolvent trading (s 588G) (Incorporated company (Corporations Act))
Check whether these apply
- Trust account audit + ASIC / state regulator submission: only if you hold money in a statutory trust account
- ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026: only if you meet 2 of 3 Group 2 tests (revenue ≥ $200M, gross assets ≥ $500M, 250+ employees) or report under NGER
- 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
- Track eligibility for the electric car FBT exemption: only if you provide electric vehicles to employees
- AASB S1 (general sustainability) disclosures — voluntary today, mandatory pending: only if you choose to report voluntarily under AASB S1
- Comply with AANA Code of Ethics + community guidelines: only if you advertise to consumers or engage influencers
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.Primary actionRun the compliance journeyAnswer a short questionnaire about your business and get the obligations that apply to you, with the reason each one applies.
Questions
- How many compliance obligations apply to real estate agents in Australian Capital Territory with 100–499 employees, turnover $100M–$1B?
- 72 obligations apply (26 critical) across 32 regulators, plus 12 to check. Risk rating: high. Licensed or supervised regime: AML/CTF reporting entity. These carry licence conditions, regulator audit and per-contravention civil penalties.
- Which Australian Capital Territory laws apply?
- PCBU primary duty of care (ACT WHS Act s 19), Industrial manslaughter offence (ACT WHS Act s 34A), Pay ACT payroll tax when threshold met and Comply with Workplace Privacy Act 2011 (ACT)
Related
- Real estate agents compliance in Australian Capital Territory
- Real estate agents: all obligations
- Compliance obligations by industry, state and size
- Real estate agents in ACT: sole trader
- Real estate agents in ACT: sole trader with employees
- Real estate agents in ACT: partnership
- Real estate agents in ACT: trading trust
- Real estate agents in ACT: no employees
- Real estate agents in ACT: 1–5 employees
- Real estate agents in ACT: 20–99 employees
- Real estate agents in ACT: 100–499 employees
- Real estate agents in ACT: 500+ employees, turnover $1B+
- Real estate agents in New South Wales: 100–499 employees, turnover $100M–$1B
- Real estate agents in Victoria: 100–499 employees, turnover $100M–$1B
- Real estate agents in Queensland: 100–499 employees, turnover $100M–$1B
- Real estate agents in Western Australia: 100–499 employees, turnover $100M–$1B
- Real estate agents in South Australia: 100–499 employees, turnover $100M–$1B
- Real estate agents in Tasmania: 100–499 employees, turnover $100M–$1B
- Real estate agents in Northern Territory: 100–499 employees, turnover $100M–$1B
- Enrol with AUSTRAC as a reporting entity: does it apply to real estate agents?
- Maintain a written AML/CTF program: does it apply to real estate agents?
- Customer due diligence (KYC) on every customer: does it apply to real estate agents?
- Suspicious matter, threshold, and IFTI reporting to AUSTRAC: does it apply to real estate agents?
Sources
- ACT Revenue Office: payroll tax thresholds and rates
- PCBU primary duty of care (ACT WHS Act s 19)
- Industrial manslaughter offence (ACT WHS Act s 34A)
- Comply with Workplace Privacy Act 2011 (ACT)
- 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
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.