Do real estate agents need to lodge the AUSTRAC annual compliance report (AML/CTF Act s 47)?

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.

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. Real estate agents is one of the 8 where the answer is different: yes.

The deciding fact for real estate agents: Tranche 2 industry (Real estate agents) — AML/CTF reporting entity from 1 July 2026.

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 an AML/CTF designated service).

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.

• Property management of rental income through a trust account is excluded by the Rules, so a rent-roll-only agency is not caught by that activity.
• Leases of 30 years or less, easements, mortgagee interests and standalone licences to occupy are outside the definition of real estate.

AUSTRAC publishes a real estate starter kit for agencies that broker sales only (not developers) and meet the other suitability criteria.

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)

• Customer due diligence (KYC) on every customer: Yes
• Designate an AML/CTF Compliance Officer: Yes
• Detect + enhance due diligence on Domestic + Foreign PEPs: Yes
• Enrol with AUSTRAC as a reporting entity: Yes
• Maintain a written AML/CTF program: Yes
• Suspicious matter, threshold, and IFTI reporting to AUSTRAC: Yes
• All 26 answers for real estate agents

• Accountants & bookkeepers: Yes
• Lawyers & solicitors: Yes
• Conveyancers: Yes
• Trust & company service providers: Yes
• Precious metals & stones dealers: Yes
• Banks & ADIs: Yes