Tranche 2 Guide

AUSTRAC Tranche 2: What Australian Businesses Need to Know (2026)

Tranche 2 extends AML/CTF obligations to specified professional, real estate and precious items services. Obligations began on 1 July 2026. Check the services your business provides, the geographical link and exceptions, then work through enrolment, your program, customer checks and reporting.

By AML Mate Published
Updated & sources checked

Scope
Services decide coverageAn industry or professional title alone is not the test.
Commencement
1 July 2026Obligations started for the newly regulated services.
Enrolment
29 July 2026The initial deadline has passed. New providers have an ongoing rule.

What is Tranche 2?

More services come into scope

The reforms extend the AML/CTF regime beyond existing regulated sectors to specified services often supplied by accountants, lawyers, conveyancers, trust and company service providers, real estate businesses and precious items dealers. The obligations attach to designated services, not every activity in these industries.

Find the services that match your business

Accountants and company services

Certain transaction, client money, company, trust and address services can be covered. General advice alone is not automatically a designated service.

Lawyers and conveyancers

Assess the particular professional service and its exceptions. Legal professional privilege requires separate care when reporting.

Real estate businesses

Brokering sales, purchases or transfers and business sales without an independent broker have distinct service and customer definitions.

Precious items dealers

For the precious items service, cash or virtual asset payments of at least $10,000 count, including linked transactions. Card or bank-transfer-only purchases do not trigger this service.

The dates, in order

31 March 2026

Enrolment opened for newly regulated businesses. This was the opening date, not their enrolment deadline.

1 July 2026

AML/CTF obligations commenced for the newly regulated services. Program, customer checks and other applicable obligations are already in effect.

29 July 2026

Initial enrolment deadline for businesses already providing newly regulated services. If you missed it, act promptly. New providers generally apply within 28 days after the day they start a designated service.

What does your business need to do?

Check designated services first

List the services you provide, including occasional work. Match them to the statutory definitions, geographical link and exceptions. Record your reasoning and seek advice if the application is unclear.

Enrol and assign responsibility

Businesses already providing newly regulated services had to enrol by 29 July 2026. A new provider generally applies within 28 days after the day it starts providing a designated service. Appoint an eligible compliance officer, record their authority and notify AUSTRAC within the applicable period.

Put your program into practice

Before providing designated services, establish an AML/CTF program that addresses your risks. Document your risk assessment and policies, obtain senior manager approval, train staff and set review and independent evaluation arrangements. Templates need to be customised and used in daily work.

Apply customer due diligence

Generally complete initial CDD before providing a designated service. Identify the customer, relevant beneficial owners and representatives, understand purpose and risk, and monitor over time. The treatment of eligible pre-commencement customers is different from a blanket deadline extension.

Set reporting and record procedures

Assign who recognises triggers, assesses suspicion, lodges reports and retains the relevant records. Staff need to know how and when to escalate.

What are the consequences of non-compliance?

Take obligations seriously

AUSTRAC has enforcement powers including infringement notices, remedial directions, enforceable undertakings and civil penalty proceedings. The consequences depend on the breach and circumstances. Do not treat transitional arrangements as permission to postpone all obligations.

A practical starting point for smaller businesses

Prioritise gaps in your actual work

Start with services, customers, payment methods and responsibilities. Use an appropriate starter kit where it fits, then customise, approve and implement it. Keep evidence of training, checks and decisions. Being small does not by itself remove obligations.

Use tools alongside business judgement

AML Mate helps organise program documents, customer records and report preparation. It does not submit reports to AUSTRAC or guarantee compliance. Compare plan inclusions with your needs and allow for staff time and specialist advice.

Frequently asked questions

What is AUSTRAC Tranche 2?

Tranche 2 is the extension of AML/CTF obligations to specified professional, real estate and precious items services. Coverage depends on the designated service, geographical link and applicable exceptions.

When did Tranche 2 start?

Obligations for newly regulated services began on 1 July 2026. Enrolment opened on 31 March 2026, with an initial deadline of 29 July 2026 for businesses already providing those services. New providers have an ongoing enrolment rule.

Who is affected by Tranche 2?

Businesses providing covered services can include accountants, lawyers, conveyancers, trust and company service providers, real estate businesses and precious items dealers. An industry label alone does not establish coverage.

What are the penalties for non-compliance?

AUSTRAC can use enforcement measures including infringement notices, remedial directions, enforceable undertakings and civil penalty proceedings. The applicable consequence depends on the breach and circumstances; consult the official guidance for current penalty details.

Is there a transitional period?

There are specific arrangements for particular obligations and entities, not a blanket grace period. The initial CDD transition for eligible existing reporting entities is different from the trigger-based treatment of eligible pre-commencement customers of newly regulated businesses.

Resources and sources

Official guidance checked on 14 October 2026. Follow the source for the full conditions and exceptions.

Practical follow-ups from the AML Mate blog.

AML Risk Assessment Template for Australian Businesses (2026)

A copy-ready AML/CTF risk assessment template for Tranche 2 businesses. Includes the four AUSTRAC risk factor categories, a scoring matrix, and a 30-minute step-by-step process.

5 min read

Do You Need an AML Certification for Tranche 2? What AUSTRAC Actually Requires

The global compliance industry has arrived for Australia's 90,000 newly regulated firms: certifications, conferences, training partnerships. None of it is a legal requirement. The AML/CTF Act does not require your compliance officer to hold any certification, and the training obligation is risk-based and tailored to your own program. Here is what the law actually asks of a small firm, when a certification is genuinely worth it, and where your money is better spent three weeks out from 1 July.

6 min read

Four Days to 1 July: The Rule That Changes Your Next New Client

Most of the 1 July countdown is about getting a program ready. One operational rule bites the soonest, and it reverses a habit of a lifetime: from 1 July you complete customer due diligence before you provide a designated service, not once the matter is underway. Here is what 'before' actually means for your next new client, why doing the work first and the paperwork later no longer holds, and how to make the check a quick step rather than a delay.

5 min read

Not Going to Be Perfect by 1 July? Here's What AUSTRAC Actually Expects.

With under two weeks to go, plenty of small firms know they won't have everything polished by 1 July 2026. AUSTRAC has said it plainly: it doesn't expect perfection on day one, but it does expect genuine effort to comply. That's reassuring, and it's widely misread. Genuine effort is not the same as 'we'll get to it.' Here is what the phrase actually means, the handful of obligations that get no grace at all, and the realistic minimum a small firm should have running on 1 July.

6 min read

Ready to build your AML/CTF program?

Build your program, prepare report records and keep your client checks organised.

Eligible accounts get a 14-day free trial. A card is required at checkout. Your subscription automatically renews at your selected monthly price unless you cancel before the trial ends. During the trial you can build and use your program and records in the app. Downloading the program and audit pack unlocks with your first payment, and you can start paying early at any time. Accounts that have already used a trial, or choose to skip it, start with payment.

This guide is based on AUSTRAC's publicly available guidance. It does not constitute legal or compliance advice. Consult a licensed compliance professional for complex situations.