The AML/CTF Tranche 2 reforms have extended Australia's anti-money-laundering framework to gatekeeper professions including accountants, lawyers, and real estate agents, and as of 1 July 2026 they are in force. Accounting firms that provide certain designated services are now reporting entities under the AML/CTF Act and are subject to the full regime. This is not a future obligation to plan for, it is a live one, and the immediate pressure point for any firm that has not yet acted is the enrolment deadline of 29 July 2026, which applies to every firm that was providing designated services on 1 July. The first question is not how to comply, it is whether the firm is captured at all, because that turns entirely on what the firm does rather than how large it is.
Which services actually trigger the obligation
Scope depends on the services provided, not the firm's size or revenue, and AUSTRAC frames the designated services for accounting practices around a few categories: forming or managing companies and legal arrangements, which covers setting up companies, trusts, and partnerships for clients; acting as, or arranging for someone to act as, a nominee director, trustee, partner, or nominee shareholder; and receiving, holding, or managing client funds in circumstances beyond simply collecting payment for the firm's own services. That last one is the most commonly misread. An exception applies where funds are held solely as payment for the firm's services or incidentally to a non-designated service, but using a trust account as a substitute for a client's own banking facility does not fall within that exception, so any firm holding client money beyond straightforward fee collection needs to look at that activity closely before assuming it is out.
The reassuring half of the scope question is that pure compliance work does not, on its own, capture a firm. Standard tax return preparation, BAS lodgement, and routine bookkeeping, where no entity formation or fund management is involved, are not designated services. The complication is that many mid-size firms offer more than that. Company formations, trust deed preparation, nominee director arrangements, and succession structuring all cross into designated-service territory, and it only takes one designated service, provided in the course of business, to make the whole firm a reporting entity. The obligation attaches to the activity, not the job title, which is exactly why a firm cannot reason from "we're just accountants" to "we're out." It has to map what it actually does against the designated-services list and write down the conclusion.
The program AUSTRAC expects, and the Starter Kit
Enrolment is only the notification step. The substantive obligation is a working AML/CTF program, and AUSTRAC has published an Accounting Program Starter Kit, co-designed with industry, aimed at smaller practices that provide only the professional services designated under the reforms and no other category of designated service. A firm that fits that profile can use the Starter Kit as the backbone of its program with relatively modest tailoring. It is not mandatory, but AUSTRAC actively encourages it as a compliant baseline, and it packages the pieces the regime requires: a risk assessment framework covering client types, services, and transaction patterns, plus template policies for customer due diligence, ongoing monitoring, suspicious matter reporting, staff training, and governance. In practice the program has to do a defined set of things: complete a money-laundering and terrorism-financing risk assessment specific to the firm's services and clients, document an AML/CTF program reflecting that assessment, appoint a suitably senior compliance officer who meets AUSTRAC's fit-and-proper expectations, run customer due diligence before providing a designated service to a new client, monitor existing relationships on an ongoing basis, establish a process for identifying and reporting suspicious matters, and train staff on AML/CTF risk. The program has to be approved by senior management and be operational now that obligations have commenced, and reviewed regularly as the firm's services and risk profile change. Firms already engaged with their APESB quality-management obligations often find their client-onboarding processes are part-way there, so for many this is a set of tweaks rather than a build from zero.
The enrolment deadline and what non-compliance costs
Enrolment opened on 31 March 2026 through AUSTRAC Online, and any firm that was providing designated services on 1 July 2026 must complete enrolment by 29 July 2026. That deadline is now close, and with tens of thousands of newly regulated businesses expected to enrol, the portal is busiest in the final weeks, so leaving it to the last day carries its own risk. Enrolment itself asks for basic information about the firm's structure, the designated services it provides, key personnel, and contact details, and once enrolled the firm must notify AUSTRAC of any change to those details within 14 days. Crucially, the obligation does not wait for enrolment. From 1 July it exists by operation of law for any firm providing a designated service, whether or not that firm has enrolled or built its program, and late enrolment is itself a contravention of the Act. AUSTRAC can pursue civil penalties and criminal sanctions, and the firms most exposed are precisely those that offer company formations, trust structures, or nominee services inside a broader advisory offering and have never thought of that work as financial-crime-relevant, because those are the very services AUSTRAC identifies as most commonly exploited by professional intermediaries.
The takeaway
If your firm sets up companies or trusts, acts as a nominee director, or holds client funds outside straightforward payment arrangements, you are almost certainly a reporting entity now, and the enrolment window closes on 29 July 2026. The practical sequence is unchanged by the deadline pressure, only compressed: confirm scope against AUSTRAC's designated-services list, enrol through AUSTRAC Online, build the AML/CTF program off the Accounting Program Starter Kit if you are eligible, appoint a compliance officer, stand up customer due diligence for new clients, and train the relevant staff. The regime is live, the deadline is fixed by legislation, and the safest position for any firm still unsure whether it is captured is to resolve that question this week rather than assume its way out of it.
