Who must enrol with AUSTRAC as a reporting entity?
The applicability test for Enrol with AUSTRAC as a reporting entity (AUSTRAC), computed across 35 industries, 9 business structures and 6 size bands.
Short answer: Some businesses
Applies when the business has an AML/CTF designated service. Where the business has aml adjacent, check whether you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
What the obligation is
Tranche 2 entities must enrol with AUSTRAC within 28 days of first providing a designated service (29 July 2026 for services from 1 July 2026).
Since 1 July 2026, the Tranche 2 expansion has captured real estate agents, accountants, lawyers, conveyancers, trust & company service providers, and precious metals dealers when providing 'designated services'. Enrolment opened on 31 March 2026; a reporting entity must enrol with AUSTRAC within 28 days of first providing a designated service (29 July 2026 for businesses providing designated services from 1 July 2026). Each day a designated service is provided while unenrolled can be a separate civil penalty contravention. AUSTRAC began issuing notices to apparently unenrolled real estate agents, accountants, lawyers and jewellers on 28 August 2026.
The applicability test
Applies when the business has an AML/CTF designated service. Where the business has aml adjacent, check whether you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
How the regulator frames it: Any entity providing a 'designated service' as defined in the AML/CTF Act 2006, including the six Tranche 2 sectors from 1 July 2026.
What triggers it: Providing a designated service for the first time, or being captured by Tranche 2 reforms from 1 July 2026.
Threshold: Providing a designated service (no monetary threshold for enrolment).
Jurisdiction: Commonwealth law, so the test is the same in every state and territory.
Which industries are in or out
Outcome across the 35 industries Rules Mate maps (8 of 35: yes; 27 of 35: no).
| Industry | Answer |
|---|---|
| Real estate agents | Yes |
| Accountants & bookkeepers | Yes |
| Lawyers & solicitors | Yes |
| Conveyancers | Yes |
| Trust & company service providers | Yes |
| Precious metals & stones dealers | Yes |
| Banks & ADIs | Yes |
| Gambling & wagering | Yes |
| No | 27 other industries |
Business structure and size
Structure does not change the answer in the 8 industries it can reach: for every structure the answer is "yes".
Size does not change the answer in the 8 industries it can reach: at every size band the answer is "yes".
Worked examples
Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:
- Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: applies. Tranche 2 industry (Real estate agents) — AML/CTF reporting entity from 1 July 2026.
- Pty Ltd company in fintech (non-bank) with 6–19 employees, turnover $1M–$3M: does not apply. Requires an AML/CTF designated service.
Answers that bring it into scope
Starting from a small or large professional services company that does not otherwise meet the test, each of these single facts changes the engine's answer:
- The business holds an Australian financial services licence (AFSL): it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
- The business issues financial products or gives financial product advice: it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
- The business holds an Australian credit licence (ACL): it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
- The business provides credit to customers: it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
- The business deals in crypto-assets or runs a digital currency exchange: it then applies (digital currency exchange / virtual asset services — AML/CTF reporting entity).
- The business receives large physical cash payments: it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
- The business makes or receives international funds transfers: it becomes worth checking, because it applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
When you need to check further
The engine shows this obligation as "check whether this applies" when a business has aml adjacent. It then applies only if you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3). That fact is not something Rules Mate can infer from industry, structure or size.
What you must do, and when
- When due
- Within 28 days of first providing a designated service. Tranche 2 entities providing designated services from 1 July 2026: 29 July 2026 (passed — enrol now if you have not).
- Frequency
- One-off
- Evidence to keep
- AUSTRAC reporting entity enrolment confirmation, business activity profile, key personnel attestations.
- In force from
- 1 July 2026
- Status
- Current
- Priority
- Critical
Penalty for not complying
Maximum penalty: Each day unenrolled can be a separate contravention. Infringement notice: $21,840 (company) or $4,368 (individual) per contravention; or a civil penalty of up to $36.4M (body corporate) / $7.28M (individual), maximum per contravention.
Audit or assurance level
Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.
Dates in the compliance calendar
- AML/CTF Tranche 2 commences: 1 July 2026 (one-off). AML/CTF Act extends to Tranche 2 sectors. Enrolment + program + CDD + reporting obligations begin.
- AUSTRAC enrolment deadline (Tranche 2): 29 July 2026 (one-off). Last day to complete AUSTRAC enrolment if you provided a designated service on day one of Tranche 2.
Obligations with the same applicability test
If this obligation applies to you, so do these 7: the engine uses the same rule for each.
- Maintain a written AML/CTF program
- Customer due diligence (KYC) on every customer
- Suspicious matter, threshold, and IFTI reporting to AUSTRAC
- Independent review of AML/CTF program
- Designate an AML/CTF Compliance Officer
- Detect + enhance due diligence on Domestic + Foreign PEPs
- Lodge the AUSTRAC annual compliance report (AML/CTF Act s 47)
What usually applies alongside it
Across the 1,890 business profiles Rules Mate evaluates, these obligations apply to most of the businesses this one applies to, and are far more common among them than among businesses generally:
Where it sits in the corpus
Rules Mate tracks 8 published obligations tagged "aml ctf", 6 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated critical priority, and is a one-off obligation.
Regulator, legislation and tools
Regulated by Australian Transaction Reports and Analysis Centre.
AUSTRAC: Anti-money laundering and counter-terrorism financing regulator and financial intelligence unit. Administers the AML/CTF Act, including Tranche 2 expansion from 1 July 2026.
AML/CTF Act: Federal AML/CTF regulation.
Free tools that help with this obligation:
Questions
- Who must enrol with AUSTRAC as a reporting entity?
- Applies when the business has an AML/CTF designated service. Where the business has aml adjacent, check whether you provide an AML/CTF designated service (AML/CTF Act s 6 tables 1–3).
- Do sole traders need to enrol with AUSTRAC as a reporting entity?
- Yes. Looking in the 8 industries it can reach and every size band, the engine's answer for a sole trader is: yes.
- Do businesses with 1–5 employees need to enrol with AUSTRAC as a reporting entity?
- Yes (1–5 employees, turnover $100K–$1M).
- When is "Enrol with AUSTRAC as a reporting entity" due?
- Within 28 days of first providing a designated service. Tranche 2 entities providing designated services from 1 July 2026: 29 July 2026 (passed — enrol now if you have not).
Related
- Enrol with AUSTRAC as a reporting entity: full obligation detail
- Who must comply: all obligations
- Who must maintain a written AML/CTF program
- Who must comply with Customer due diligence (KYC) on every customer
- Who must comply with Suspicious matter, threshold, and IFTI reporting to AUSTRAC
- Does it apply to real estate agents?
- Does it apply to accountants & bookkeepers?
- Does it apply to lawyers & solicitors?
- Does it apply to conveyancers?
- Does it apply to trust & company service providers?
- Does it apply to precious metals & stones dealers?
- AML/CTF Tranche 2 guides
Sources
- AUSTRAC: official source
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006
- AUSTRAC guidance
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.