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Rules Mate

Does APP 12 & APP 13 access and correction requests apply to real estate agents?

A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.

Short answer: Yes

Yes. This obligation applies to real estate agents whatever their structure or size. The deciding fact: AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A)).

The obligation in brief

APP 12 & APP 13 access and correction requests. APP 12 requires entities to give an individual access to their personal information held by the entity on request, within 30 days (private sector). g.

Trigger: Receiving an access or correction request.

Why real estate agents get a different answer

Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 24 of those industries the answer for "APP 12 & APP 13 access and correction requests" is it depends on structure or size. Real estate agents is one of the 11 where the answer is different: yes.

The deciding fact for real estate agents: AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A))

About the industry: Selling agents, buyer's agents, and property developers involved in real estate transactions. From 1 July 2026 captured by AML/CTF Tranche 2 reforms.

Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires APP-entity status (turnover > $3M or a s 6D(4) carve-out)).

Answer by business structure and size

Each cell is the engine's outcome for a business in real estate agents with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.

"APP 12 & APP 13 access and correction requests": outcome for real estate agents by structure and size
StructureNo employees1–5 employees6–19 employees20–99 employees100–499 employees500+ employees
Sole traderYesYesYesYesYesYes
PartnershipYesYesYesYesYesYes
TrustYesYesYesYesYesYes
Pty Ltd companyYesYesYesYesYesYes
Public companyYesYesYesYesYesYes
Not-for-profit (unregistered)YesYesYesYesYesYes
Registered charityYesYesYesYesYesYes
Super fundYesYesYesYesYesYes
Foreign companyYesYesYesYesYesYes

What the obligation requires

When due
Access: 30 days (private sector). Correction: reasonable timeframe; statement of correction if disagreement.
Evidence to keep
Request register, response letters, correction logs.
Maximum penalty
Civil penalty exposure for systemic failure to respond; complaint-handling by OAIC
Regulator
OAIC
Jurisdiction
Commonwealth (national)

Other obligations where real estate agents differ from the norm

Other industries with a non-default answer

Questions

Does APP 12 & APP 13 access and correction requests apply to real estate agents?
Yes. This obligation applies to real estate agents whatever their structure or size. The deciding fact: AML/CTF reporting entity — covered by the Privacy Act for AML/CTF activities (s 6E(1A)).
Is the answer the same for every industry?
No. For 24 of the 35 industries Rules Mate maps, the answer is it depends on structure or size. Real estate agents is one of 11 industries with a different answer.

Related

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.