A client incorporates a company. They are running it from a spare room, or from a co-working desk, or from a house in a suburb they would rather not put on a public register. They ask whether the ASIC form can list your office instead. You say yes, because you have said yes a hundred times, because you are already lodging their annual review, and because it costs you nothing but the occasional envelope.
That is a designated service. Not the annual review, not the tax work, not the constitution you drafted. The address.
AUSTRAC has said so since table 6 was written, but on 3 September 2026 it added a full section to its professional designated services guidance setting out how item 9 actually works: when it starts, who the customer is, and the one distinction that decides whether you are providing it at all (AUSTRAC, professional designated services, updated 3 September 2026). If your firm holds the mail for a handful of client companies, this is the six-day-old guidance to read.
What Item 9 Says
Table 6 of subsection 6(5B) of the Act lists the professional designated services. Item 1 is assisting with a real estate transaction. Item 5 is selling a shelf company. Item 9, the last one, is:
providing a registered office address or principal place of business address of a body corporate or legal arrangement, in the course of carrying on a business
The customer is "the person to whom the service is provided." (AUSTRAC, professional designated services)
Three things in that line do a lot of work. It is about a body corporate or legal arrangement, so a sole trader borrowing your address is not item 9. It has to be in the course of carrying on a business, so the favour you do for your brother-in-law outside the practice is not captured. And it is the address that is the service, full stop. Nothing else has to happen. You do not have to lodge anything, hold anything, or advise on anything.
Most firms reading the designated service list in June scanned item 9, thought "that's for company service providers", and moved on. We wrote in July about why the test is the service and not the job title. Item 9 is the sharpest example of that in the whole table, because the firms providing it mostly do not think of themselves as providing anything.
The Two-Part Test, and the Distinction That Decides It
AUSTRAC's new section says the service applies where both of the following are true:
- You provide the address to a customer for use, or intended use, as the registered office address or principal place of business address of a body corporate or legal arrangement.
- The body corporate or legal arrangement uses, or intends to use, this address in place of an address from which they operate their business.
(AUSTRAC, professional designated services)
Limb two is the whole distinction, and AUSTRAC illustrates it with an example worth walking through slowly.
An individual registers Company A with ASIC as a new online business. They ask an accounting firm if Company A can use the firm's address as its registered office. Company A actually operates from a separate building, leased to it by Company B, and it never uses or occupies the accounting firm's premises.
The accounting firm is providing an item 9 designated service to Company A. It has made its address available to be used in place of the address Company A operates from.
Company B is not, even though it is also providing Company A with an address. Company B is providing the address Company A operates from. That is a lease, not item 9.
So the question is never "does a company use my address?" It is "does a company use my address instead of where it really is?" Your landlord is not caught. You, holding the mail for a company that has never set foot in your building, are.
The Four Details That Catch People
It does not matter whether you charge. AUSTRAC's wording is flat: "It doesn't matter whether you provide the service for a fee or free of charge." The courtesy version and the $220-a-year version are the same designated service. This is the single most common way firms talk themselves out of item 9, and it does not work.
It starts before ASIC ever sees it. You begin providing the service "when you make an address available to a customer for use, or intended use." AUSTRAC's example: where a customer intends to use the address when incorporating a company, the service starts when the address is made available, "even if they haven't yet provided the address to ASIC." The email where you write "sure, use ours" is the trigger, not the lodgement.
The customer is the company, not the person who asked. Where you provide an address for a company to use as its registered office, the company is the customer. That matters enormously for what you have to do next, because your customer is a body corporate, which means beneficial owners and the people acting on the company's behalf, not just the director who sent the email. AUSTRAC has a dedicated guide for initial CDD where the customer is a body corporate.
Overseas counts, and a PO box does not. The service also applies to providing equivalent addresses outside Australia. And AUSTRAC has clarified the terms themselves: a registered office address and a principal place of business address "must be a physical street address, rather than a post office box (PO box)." A registered office address is the one recorded with ASIC, the address government bodies use to send official notices. A principal place of business address is generally the main physical address the entity operates from. (AUSTRAC, professional designated services)
AUSTRAC also names the innocent reasons a client asks. They may want it for privacy or commercial reasons, or because the entity has no physical presence in Australia. Neither is a red flag on its own. Both are reasons the service exists.
Why AUSTRAC Put It in Table 6
The reason is in your own starter kit, if you have opened it. The accounting risk assessment describes item 9 as what happens "when a practice provides a body corporate with a registered office address or principal place of business address instead of the address the person operates their business from," and then explains the risk:
Criminals can use this service to appear legitimate and make it seem like the business is operating in a different location to where it's located. This allows them to distance themselves from illicit activities, making it difficult to identify beneficial ownership.
It adds that the service "can facilitate the use of complex legal structures with ties to overseas jurisdictions," which could help move illicit funds to high-risk countries. (AUSTRAC, accounting program starter kit; the same wording sits in the legal profession kit)
Put plainly: a reputable firm's address on a public register is a credential. It is the cheapest respectability a shell entity can buy, and it is why the straw director pattern so often comes with a professional office address attached. AUSTRAC is not accusing you of anything. It is telling you that you are the one holding the credential, so you are the one who has to know who you handed it to.
If Item 9 Is the Only Designated Service You Provide
This is the part that stops people mid-sentence. There is no threshold, no minimum number of companies, and no carve-out for the small end. If you provide one or more designated services with a geographical link to Australia, you have AML/CTF obligations and you must enrol (AUSTRAC, enrol with us).
A bookkeeping practice that provides no other designated service, but holds the registered office for four client companies, is a reporting entity. So is a two-partner law firm that does no conveyancing and no company work beyond letting three clients use its street address.
The obligations that follow are the ordinary ones, on the ordinary clock:
- Enrol no later than 28 days after the day you start providing a designated service (AUSTRAC, enrol with us).
- Appoint an AML/CTF compliance officer within 28 days of providing designated services, and notify AUSTRAC within 14 days of the appointment (AUSTRAC, AML/CTF compliance officer). In a firm this size that is usually one person wearing several hats.
- Have the program, and do the CDD. Initial CDD must be completed before you start providing a customer with a designated service (AUSTRAC, overview of initial CDD). For item 9 that means before you make the address available, not before you lodge the form.
Lawyers should note one thing before assuming they are captured. Exemptions exist for a range of providers, including legal aid commissions, community legal centres and barristers acting for Australian government bodies (AUSTRAC, exemptions from AML/CTF obligations). Check whether one applies to you before you build a program you do not need.
The Uncomfortable Arithmetic for Existing Arrangements
Obligations commenced on 1 July 2026. Enrolment closed on 29 July 2026. If your firm has been holding a client company's registered office since 2019, you did not start providing a designated service in September. You were providing it on 1 July, and the enrolment window has been shut for six weeks.
That is not a comfortable sentence, and it is better read now than in a letter. AUSTRAC has already begun issuing section 167 notices to businesses that appear to be providing designated services but never enrolled. The practical answer if you are late is the same as it was in July: enrol, do not wait until the program is perfect, and be able to show the work in progress. We set that out in what AUSTRAC expects from firms that were not ready.
There is one piece of relief here, and it is real. If the company was already your customer in an ongoing business relationship on 1 July 2026 and you provide it only Tranche 2 services, it is very likely a pre-commencement customer. There is no fixed deadline to complete initial CDD on pre-commencement customers. It is trigger-based instead: if an SMR obligation arises, or a significant change in the relationship pushes the risk to medium or high, you do the CDD before the next designated service. Ongoing monitoring applies from day one regardless. The full rule, and the "30 March 2029" myth it is often confused with, is in our piece on pre-commencement customers.
So the backlog of twelve companies whose mail you have held for years does not all need verifying this month. The new one that emails you next Tuesday does, before you say yes.
What to Do This Week
- List every entity using your address. Your company secretarial register or your ASIC agent portal already has this. For each one, answer limb two: does this company operate from somewhere else? If yes, that is item 9.
- Include the freebies and the dormant ones. No fee is not a defence, and a dormant company still has a registered office. If you stopped acting for a client but never removed your address from their ASIC record, sort that out now, because on the public register you are still providing it.
- Decide whether you are enrolled, and fix it if not. If item 9 turns out to be your only designated service, you are still in. The enrolment walkthrough is unchanged, deadline aside. If your enrolment exists but does not mention the services you actually provide, you have 14 days to update it once you know.
- Write item 9 into your risk assessment. It is already a row in the accounting, legal and conveyancing starter kit risk assessments, with the risk wording drafted for you. Answer the yes/no, and rate it. A blanket low without reasons is not a risk assessment.
- Build one rule for new requests. "We do not make our address available to a company until initial CDD on that company is complete" is a single sentence in your policies that closes the whole exposure going forward. The company is the customer, so that means identifying it, its beneficial owners and anyone acting for it.
Where AML Mate Fits
AML Mate treats each entity you provide a service to as its own client file, so the company whose only connection to your firm is a line on an ASIC record still has a risk rating, a CDD record and a review date sitting where an examiner would look for them. The free compliance check takes about five minutes and will tell you whether your program covers the services you actually provide, rather than the ones you meant to.
Item 9 is the quietest designated service in table 6. There is no transaction, no money moves, and nothing arrives in your trust account. There is just an address, on a public register, borrowed from a firm whose name means something. AUSTRAC spent 3 September explaining exactly that, which is a fair signal it expects the sector to have noticed by now.
This article is general information, not legal advice. For advice specific to your circumstances, consult a qualified AML/CTF professional.