Regulatory Update

Enrolment Closes 29 July. Your Obligations Started 1 July. Is Your Program Underway?

Published 8 July 2026

The sequencing of Tranche 2 is counterintuitive, and it's worth being clear about it. AML/CTF obligations commenced 1 July 2026. Enrolment with AUSTRAC closes 29 July. AUSTRAC allowed enrolment before the obligations went live — but for practices that haven't enrolled yet, the obligations are already running and the enrolment window is still open.

If your practice provides a designated service, you have been a reporting entity since 1 July. Every practice that qualifies is in the same position: the law is already live, and the compliance program should already be underway.

The enrolment deadline is not the starting line. Enrolment is how you formally register with AUSTRAC — it doesn't create the obligation, and it doesn't start the clock. That happened on 1 July.

AUSTRAC has indicated it will take reasonable implementation timeframes and genuine best efforts into account. But "best efforts" means your program is underway — not sitting untouched until the enrolment window closes.

What your practice should be doing right now

If you're not sure where to start, here's the logical sequence — and where enrolment actually sits within it:

MINS 1–5 Confirm you're in scope. Use AUSTRAC's eligibility checker at austrac.gov.au to confirm whether your services are designated services. If they are, the rest of this list applies.

MINS 6–8 Download AUSTRAC's free Accounting Program Starter Kit. This is AUSTRAC's own guidance for small practices. It's the foundation your compliance program needs to be built on.

MINS 9–12 Confirm who your AML Compliance Officer is. In most small practices, this is the principal. They need to be identified before the program can be built — and before staff training can be assigned.

MINS 13–16 Enrol with AUSTRAC before 29 July. Once you've confirmed scope and identified your AMLCO, enrolment itself is straightforward. It's one step in the process — complete it and move on.

MINS 17–20 Get your staff training underway. Obligations began 1 July — "we'll get to it" is not a compliance position. Staff awareness training is a core requirement, and it needs to be on record. That last one is where we come in.

A note on the enrolment numbers

AUSTRAC's most recent update showed enrolments in accounting and professional services jumping from 6,590 to 9,550 between early June and early July — almost 3,000 practices in under a month, the biggest surge of any regulated sector. A significant wave likely remains.

If your practice is in that wave, the sequence above is the fastest path from "haven't started" to "program underway." Enrolment is step four, not step one.

↓ Get started today

The GET-READY Bundle — built for small practices that need to move quickly.

$250 for a practice of up to three staff, $50 per additional seat.

✓ AMLCO Support Kit — risk assessment templates, policies, and procedures
✓ Client communications pack and Customer IDV Guide included
✓ Staff awareness training with individual certificates of completion
✓ 3 seats included — $50 per additional seat

Buy the GET-READY Bundle — get started now

Questions? Visit our FAQ or get in touch.

We'll be back again later with a look at the parts of Tranche 2 most practices don't realise are in there.

← Back to Issue 1: Do the new AUSTRAC laws actually apply to your accounting practice?
← Back to Issue 2: What even is a 'designated service'?
← Back to Issue 3: DIY, consultant, or head in the sand