Transitional rules Guide

AML/CTF Transitional Rules: What You Need to Know

Transitional rules give specified entities extra time for particular obligations. They do not postpone the whole AML/CTF regime. Identify when your business was enrolled, which services it provides and the obligation involved before relying on an extension.

By AML Mate
Updated & sources checked

First principle
No blanket grace periodEach arrangement has its own eligibility and conditions.
Key distinction
Business versus customerExisting entities and existing customers have different rules.
Your next action
Record the applicable ruleKeep evidence, policy decisions and your actual deadline.

Two different customer due diligence arrangements

Existing reporting entities

Entities enrolled on 30 March 2026 that maintain qualifying pre-reform identification policies may use the initial CDD transition. Transitional policies had to identify customer classes and transition dates by 1 July 2026. The initial CDD transitional policy provision ceases to have effect on 31 March 2029; plan to transition before that date. Each customer class must use one framework at a time. New ongoing CDD obligations still apply from 31 March 2026.

Pre-commencement customers

For newly regulated services, eligible customers from an existing designated-service relationship have trigger-based initial CDD treatment, not a general 2029 deadline. Initial CDD is required if an SMR obligation arises, or a significant change in the nature and purpose of the relationship results in medium or high risk. Complete it before the next designated service. Ongoing CDD still applies.

What to record

Record the customer relationship and service dates, which rule applies, any trigger and the decision made. A name already in your database is not enough to establish pre-commencement status.

Compliance officer notification

Enrolled on 30 March 2026

The transitional notification deadline was 30 May 2026. This is not the Tranche 2 deadline.

Newly regulated business

Notify AUSTRAC by the later of 14 days after enrolment and 29 July 2026. For example, enrolment on 29 July 2026 gave a notification deadline of 12 August 2026. After the transition, the standard 14-day notification rule applies.

Find your first independent evaluation deadline

For newly regulated businesses and entities previously providing only item 54 services, the transitional schedule uses the last two digits of the AUSTRAC account number (AAN). Read the digits from left to right.

Odd / odd: 30 June 2029

Both the second-last digit and the last digit are odd. For example, an AAN ending in 13.

Odd / even: 31 December 2029

The second-last digit is odd and the last digit is even. For example, an AAN ending in 12.

Even / even: 30 June 2030

Both digits are even. Zero is even. For example, an AAN ending in 20.

Even / odd: 31 December 2030

The second-last digit is even and the last digit is odd. For example, an AAN ending in 21.

Existing entities with a prior independent review

If enrolled on 30 March 2026 with at least one pre-reform independent review, conduct the first independent evaluation by the later of four years after the most recent review and 31 March 2027. Set the evaluation frequency in your policies and check the official rule for your circumstances.

Enrolment and registration roll-over

Existing status continues

Existing enrolled entities do not need to enrol again. Existing remittance registration status continues. Registered digital currency exchange providers automatically became registered virtual asset service providers from 31 March 2026. This does not give every reporting entity a registration or permission for every registrable service.

Virtual asset and international transfer transitions

The initial service deferral has ended

Certain obligations for new registrable virtual asset services were deferred until 1 July 2026. The deferral excluded item 50A exchange services, which had to meet the new obligations from 31 March 2026. It is not a current exemption from program, CDD or reporting requirements.

IFTI to IVTS reporting

Continue the applicable IFTI reporting until the IVTS transition date, generally 31 March 2029. Some eligible providers can nominate a later date up to 30 September 2029, with notice and service-specific conditions. Providers involving virtual assets have additional restrictions on choosing a later date.

Unverified self-hosted wallets

The specific reporting obligation is deferred until 31 March 2029 for relevant services started before that date. This does not defer SMRs or other applicable obligations. Check the official guidance for the exact service and reporting conditions.

Financial advisers: a specific, expired transition

Check the item 54 conditions

The transition applied to eligible AFS licensees that only provided item 54 arranging services before 31 March 2026 and then provided table 6 professional services. It allowed reduced program and governance requirements until 30 June 2026. Full obligations for those professional services apply from 1 July 2026. It did not newly regulate every financial adviser.

Turn the applicable rule into a dated action

Establish eligibility

Record your enrolment date, designated services and the specific rule you rely on. Distinguish a business transition from a customer exception.

Update policies and responsibilities

Record the applicable deadline, evidence and responsible person. Keep other obligations operating. If a deadline has passed, address the gap promptly rather than treating the transition as still open.

Use the relevant guide

Review the official rules and seek advice where your position is unclear. The guide below explains the wider Tranche 2 framework.

Frequently asked questions

Do transitional rules postpone all AML/CTF obligations?

No. Each arrangement applies only to specified entities, services or obligations. Check its conditions and dates. Other obligations continue to apply.

Do Tranche 2 businesses have until 2029 to check existing clients?

There is no blanket 2029 initial CDD deadline for their existing clients. Eligible pre-commencement customers have trigger-based treatment, while ongoing CDD still applies. The initial CDD transition for eligible existing reporting entities is a different rule.

How do I find my first independent evaluation deadline?

For newly regulated businesses and eligible former item 54 providers, use the last two AAN digits: odd/odd gives 30 June 2029, odd/even 31 December 2029, even/even 30 June 2030 and even/odd 31 December 2030. Existing entities with a prior review have a different rule.

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.