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Rules Mate

Do accountants and bookkeepers need to lodge the AUSTRAC annual compliance report (AML/CTF Act s 47)?

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 accountants and bookkeepers whatever their structure or size. The deciding fact: Tranche 2 industry (Accountants & bookkeepers) — AML/CTF reporting entity from 1 July 2026.

The obligation in brief

Lodge the AUSTRAC annual compliance report (AML/CTF Act s 47). Section 47 of the AML/CTF Act requires a reporting entity to give the AUSTRAC CEO, within the lodgment period, a report on its compliance with the Act, the regulations and the AML/CTF Rules during the reporting period (Rules s 9-9). AUSTRAC has moved the reporting period to financial years: the next period is 1 July 2026 to 30 June 2027, and reports are lodged between 1 July and 30 September each year.

Trigger: Being a reporting entity at any time during the reporting period.

Why accountants & bookkeepers 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 27 of those industries the answer for "Lodge the AUSTRAC annual compliance report (AML/CTF Act s 47)" is no. Accountants & bookkeepers is one of the 8 where the answer is different: yes.

The deciding fact for accountants and bookkeepers: Tranche 2 industry (Accountants & bookkeepers) — AML/CTF reporting entity from 1 July 2026.

About the industry: Professional accounting and bookkeeping firms. Captured by Tranche 2 when providing designated services such as managing client money or company formation.

Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires an AML/CTF designated service).

Answer by business structure and size

Each cell is the engine's outcome for a business in accountants & bookkeepers 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.

"Lodge the AUSTRAC annual compliance report (AML/CTF Act s 47)": outcome for accountants and bookkeepers 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

Designated services that catch accountants & bookkeepers

AML/CTF Act referenceServiceCustomer for due diligence
s 6 table 6 items 2–4Assisting with the sale or purchase of a body corporate or legal arrangement; holding, controlling or managing client money or property for a transaction; equity or debt financingThe person assisted
s 6 table 6 items 5–9Selling shelf companies; creating or restructuring companies and trusts; acting as, or arranging for someone to act as, a director, secretary, trustee, partner or corporate power of attorney; acting as a nominee shareholder; providing a registered office or principal place of business addressVaries: for company creation, the proposed beneficial owners and directors; for an express trust, the trustee, settlor and beneficiaries; for nominee and officer services, the nominator
s 6 table 6 item 1Assisting a person to plan or execute a real estate transaction (not under a court order)The person assisted
  • Payments for the bookkeeper's own fees are excluded from item 3 (s 6(5C)–(5D)).
  • Incidental payments where the practice provides no other designated service, such as a bookkeeper's routine payments for a client, are excluded from item 3.
  • Payments to or from government, courts or licensed insurers are excluded from item 3.

AUSTRAC's accountant starter kit is written for small accounting practices. Before relying on it, test the practice against the kit's "who the starter kit is for" criteria, including the 15-personnel limit.

What the obligation requires

When due
Annually between 1 July and 30 September for the financial year just ended. First Tranche 2 report: period 1 July 2026 – 30 June 2027, due 30 September 2027.
Evidence to keep
Lodged compliance report and AUSTRAC Online receipt; the evidence behind each answer (AML/CTF program and approvals, risk assessment reviews, CDD records, SMR/TTR lodgment records, training records, independent evaluation report or schedule); AUSTRAC Online administrator nominated.
Maximum penalty
Section 47(2) is a civil penalty provision: up to $36.4M (body corporate) or $7.28M (other persons) per contravention. AUSTRAC can also issue an infringement notice of $21,840 (company) or $4,368 (individual), or a remedial direction. In May 2026 the Federal Court ordered two securities firms that did not pay AUSTRAC infringement notices for missed 2023 compliance reports to pay $50,000 and $45,000 plus costs.
Regulator
AUSTRAC
Jurisdiction
Commonwealth (national)

Other obligations where accountants & bookkeepers differ from the norm

Other industries with a non-default answer

Questions

Do accountants and bookkeepers need to lodge the AUSTRAC annual compliance report (AML/CTF Act s 47)?
Yes. This obligation applies to accountants and bookkeepers whatever their structure or size. The deciding fact: Tranche 2 industry (Accountants & bookkeepers) — AML/CTF reporting entity from 1 July 2026.
Is the answer the same for every industry?
No. For 27 of the 35 industries Rules Mate maps, the answer is no. Accountants & bookkeepers is one of 8 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.