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.