Real estate agents compliance obligations in Victoria: 100–499 employees
Computed by the Rules Mate applicability engine for a Pty Ltd company with 100–499 employees, turnover $10M–$100M, in real estate agents, operating in Victoria and selling to consumers and small businesses.
Short answer: 64 obligations
64 obligations apply (25 critical) across 30 regulators, plus 20 to check. Risk rating: high. Licensed or supervised regime: AML/CTF reporting entity. These carry licence conditions, regulator audit and per-contravention civil penalties.
What changes at 100–499 employees
Compared with a real estate agents business with 20–99 employees in Victoria, 3 obligations apply that did not, and 1 drops away.
What switches on at 500+ employees
Moving to a Pty Ltd company with 500+ employees, turnover $100M–$1B adds 10 obligations:
- AASB S2 Scope 3 emissions + assurance phase-in
- Lodge mandatory climate-related financial disclosures (ASRS S2)
- Publish an annual Modern Slavery Statement
- Maintain auditor / financial reporting (Chapter 2M)
- Comply with corporate whistleblower protections (Part 9.4AAA Corporations Act)
- Lodge Payment Times Reports (large business)
- ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027
- Scope 3 emissions disclosure (AASB S2 + voluntary)
- Modern Slavery Statement (Cwlth)
- Climate scenario analysis (AASB S2)
Victoria law that applies
6 Victoria obligations apply on these facts, and 1 more is worth checking:
| Obligation | Why it applies |
|---|---|
| Notify VIC WorkSafe of notifiable WHS incidents | Every PCBU must notify the regulator of notifiable incidents (death, serious injury, dangerous incident) · VIC law |
| PCBU primary duty of care (Victoria OHS Act s 21) | Every business is a PCBU — the primary duty of care applies whether or not you employ anyone · VIC law |
| Pay Victorian payroll tax when threshold met | 100–499 employees — wages far exceed the VIC payroll tax threshold of $1M |
| Comply with the General Environmental Duty (VIC) | The Victorian general environmental duty applies to every business activity that could cause harm from pollution or waste · VIC law |
| Pay long service leave under the LSL Act 2018 (Vic) | You have employees (100–499) · VIC law |
| Underquoting prohibition (Vic Estate Agents Act 1980) | Industry: Real estate agents · VIC law |
| Comply with Residential Tenancies Act 1997 (VIC) | Check: applies only if you manage residential rental properties |
Payroll tax in Victoria (FY2026-27)
VIC: 4.85% on Australian wages above the $1 million tax-free threshold (FY2026-27). On these facts it applies: 100–499 employees — wages far exceed the VIC payroll tax threshold of $1M.
- How the threshold works
- Full threshold below $3M of Australian wages; between $3M and $5M it phases out at 50% of wages over $3M; no threshold above $5M.
- Surcharges
- Above $10M Australian wages: mental health and wellbeing surcharge 0.5% + COVID-19 debt surcharge 0.5%; above $100M a further 0.5% each (2% total).
- Regional concession
- 1.2125% regional employer rate
- Returns
- Monthly by the 7th of the following month; annual reconciliation by 21 July
- Administered by
- SRO Vic
Victoria regulators
Where the obligations sit
| Area | Obligations |
|---|---|
| Aml ctf | 8 |
| Privacy | 8 |
| Workplace | 8 |
| Tax | 7 |
| Directors | 4 |
| Whs | 4 |
| Super | 2 |
| Real estate | 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
- AASB S2 Scope 3 emissions + assurance phase-in: only if you meet 2 of 3 ASRS size tests (revenue ≥ $50M, gross assets ≥ $25M, 100+ employees) or report under NGER
- Lodge mandatory climate-related financial disclosures (ASRS S2): only if you meet 2 of 3 ASRS size tests (revenue ≥ $50M, gross assets ≥ $25M, 100+ 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
- Maintain auditor / financial reporting (Chapter 2M): only if you meet 2 of 3 large-proprietary tests (revenue ≥ $50M, gross assets ≥ $25M, 100+ employees)
- Comply with corporate whistleblower protections (Part 9.4AAA Corporations Act): only if you are a large proprietary company (s 1317AI policy requirement)
Thresholds to watch
- Modern Slavery Statement mandatory (threshold $100M consolidated; approaching)
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 Victoria with 100–499 employees?
- 64 obligations apply (25 critical) across 30 regulators, plus 20 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 Victoria laws apply?
- Notify VIC WorkSafe of notifiable WHS incidents, PCBU primary duty of care (Victoria OHS Act s 21), Pay Victorian payroll tax when threshold met, Comply with the General Environmental Duty (VIC), Pay long service leave under the LSL Act 2018 (Vic) and Underquoting prohibition (Vic Estate Agents Act 1980)
Related
- Real estate agents compliance in Victoria
- Real estate agents: all obligations
- Compliance obligations by industry, state and size
- Real estate agents in VIC: sole trader
- Real estate agents in VIC: sole trader with employees
- Real estate agents in VIC: partnership
- Real estate agents in VIC: trading trust
- Real estate agents in VIC: no employees
- Real estate agents in VIC: 1–5 employees
- Real estate agents in VIC: 20–99 employees
- Real estate agents in VIC: 100–499 employees, turnover $100M–$1B
- Real estate agents in VIC: 500+ employees, turnover $1B+
- Real estate agents in New South Wales: 100–499 employees
- Real estate agents in Queensland: 100–499 employees
- Real estate agents in Western Australia: 100–499 employees
- Real estate agents in South Australia: 100–499 employees
- Real estate agents in Tasmania: 100–499 employees
- Real estate agents in Northern Territory: 100–499 employees
- Real estate agents in Australian Capital Territory: 100–499 employees
- 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
- SRO Vic: payroll tax thresholds and rates
- Notify VIC WorkSafe of notifiable WHS incidents
- PCBU primary duty of care (Victoria OHS Act s 21)
- Comply with the General Environmental Duty (VIC)
- Pay long service leave under the LSL Act 2018 (Vic)
- Underquoting prohibition (Vic Estate Agents Act 1980)
- Enrol with AUSTRAC as a reporting entity
- Customer due diligence (KYC) on every customer
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.