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.