From 1 July 2026, thousands of Australian accounting firms will become reporting entities under the AML/CTF Act 2006. This is known as the Tranche 2 expansion — and if your firm provides accounting, bookkeeping, or advisory services, it almost certainly applies to you.
What Does Tranche 2 Mean?
AUSTRAC’s Tranche 2 reforms extend AML/CTF obligations to accounting firms, lawyers, real estate agents, and trust and company service providers. For accounting firms this means new statutory obligations across your entire client base.
- Enroll with AUSTRAC as a reporting entity
- Develop and maintain an AML/CTF Program
- Conduct customer due diligence on all clients
- Perform identity verification before providing services
- Screen clients against PEP, sanctions, and adverse media lists
- Report Suspicious Matter Reports to AUSTRAC when required
- Keep records for 7 years
- Submit an Annual Compliance Report to AUSTRAC
When Does It Start?
⚠️ Deadline Reminder: Your firm must be enrolled with AUSTRAC and have an operational AML/CTF Program in place by 1 July 2026. There is no grace period.
Does It Apply to Your Firm?
If your firm provides any of these services you are a reporting entity:
- Preparing or lodging tax returns
- Providing bookkeeping services
- Assisting with business sales or acquisitions
- Setting up trusts, companies, or SMSFs
- Providing financial or business advice
- Acting as a registered agent
What Happens If You Don’t Comply?
AUSTRAC has significant enforcement powers. Under Section 167 AUSTRAC can demand records from your firm. Under Section 172A your AML Compliance Officer can be compelled to attend examination under oath.
Civil penalties for non-compliance can reach up to $33.5 million for corporations.What Should Your Firm Do Now?
There are three paths to compliance before 1 July 2026:
Path 1 — DIY Starter Kit ($0–$2,000)
AUSTRAC’s free Accounting Program Starter Kit is only suitable for sole practitioners with simple client bases who pass all 8 suitability criteria. If your firm fails even one criterion the kit is not sufficient on its own.
Path 2 — Big-4 Specialist Build ($30,000–$80,000+)
A bespoke 60–100 page AML/CTF Program drafted by a specialist consultant. Thorough document but no operational system — the same evidence gap remains.
Path 3 — ComplyHub Blended ($10,000–$15,000)
A tailored AML/CTF Program plus ComplyHub configured to execute every policy automatically. Identity verification, risk scoring, PEP and sanctions screening, EDD routing, and immutable 7-year audit trail — all automated. The only path where your firm has both a defensible program AND a system that runs it day to day.
Ready to get compliant before 1 July 2026? Book a 30-minute demo with ComplyHub today.
