What’s actually changed?
Australia’s AML/CTF framework has been in place for years. But until now, it has mostly applied to banks and financial services companies. From 1 July 2026, the laws have expanded to cover a much wider group of businesses, including accountants and accounting firms.
This is often called the “Tranche 2” expansion and it’s the most significant change to Australia’s financial crime laws in almost two decades. AUSTRAC estimates that financial crime costs Australia up to $82 billion a year and the thinking is that professionals like accountants are in a unique position to spot it.
If your firm provides accounting services, you’re now a reporting entity. That means new obligations apply to you. But also new tools, resources and support from AUSTRAC to help you comply.
Your immediate to-do list
Enrolment opened on 1 July 2026. You must complete this through AUSTRAC Online by 29 July 2026. Don’t leave it to the last minute. You’ll need business details, information about your services and your earnings ready to go.
AUSTRAC’s enrolment form asks for specific details. Their guide explains exactly what you’ll need and it’s worth reading before you start so you’re not scrambling halfway through.
What you should have in place by 1 July 2026
In addition to enrolling, AUSTRAC expects firms to have already started building their compliance foundations. Here’s what that looks like:
You need a written program that describes how your firm identifies and manages money laundering and terrorism financing risks. AUSTRAC has published a program starter kit for small businesses, which is a great starting point if you haven’t developed one yet.
Someone at your firm needs to own AML/CTF compliance. This can be a principal, director or senior manager. It doesn’t have to be a dedicated role, but it does need to be a real person with real accountability.
Your team needs to understand your AML/CTF program, your firm’s internal processes and the money laundering and terrorism financing risks relevant to your work. This doesn’t have to be elaborate. AUSTRAC’s free webinar series is a solid foundation.
From 1 July 2026, you have legal obligations to report suspicious matters to AUSTRAC. Your firm needs to understand what this means and have a process for doing it. Even if it’s simple.
Key dates at a glance
ALREADY LIVE
1 July 2026
Obligations begin. Enrolment opens. Your AML/CTF program should be in place.
ENROLMENT DEADLINE
29 July 2026
Last day to enrol with AUSTRAC through AUSTRAC Online. Don’t miss this.
Your AML/CTF compliance checklist
Use this checklist to track your firm’s progress. Save this and tick each item off as you complete it.
STEP 1 — ENROLMENT
Confirm you’re in scope: Check whether your firm provides designated accounting services under the AML/CTF Act.
Create an AUSTRAC Online account: You’ll need this before you can start the enrolment form.
Gather your business information: Legal name, ACN/ABN, services provided, business structure and estimated earnings from designated services.
Identify your key personnel: Names and details of directors, partners or beneficial owners will be required in the enrolment form.
Submit your enrolment: Complete and lodge through AUSTRAC Online by 29 July 2026.
STEP 2 — AML/CTF PROGRAM
Assess your ML/TF risks: Identify the money laundering and terrorism financing risks specific to your firm’s services and client base.
Build or adopt an AML/CTF program: Use AUSTRAC’s Accounting Program Starter Kit or develop your own written, risk-based program.
Document your policies and procedures: Cover customer due diligence, ongoing monitoring and how you’ll handle suspicious matters.
STEP 3 — PEOPLE AND TRAINING
Appoint an AML/CTF Compliance Officer: Nominate a fit-and-proper person (principal, director or senior manager) to own compliance. Notify AUSTRAC by 29 July 2026.
Train your staff: Ensure your team understands the AML/CTF program, red flags to watch for and how to escalate suspicious activity.
STEP 4 — CLIENT OBLIGATIONS
Set up customer due diligence (CDD): Have a process to verify client identity before providing designated services.
Prepare for ongoing monitoring: Understand how you’ll monitor client transactions and relationships on an ongoing basis.
Know how to report suspicious matters: Have a clear internal process for escalating and submitting Suspicious Matter Reports (SMRs) to AUSTRAC.
STEP 5 — ONGOING COMPLIANCE
Schedule program reviews: Your AML/CTF program must be reviewed regularly, especially when services or risks change.
Plan your independent evaluation: Newly regulated firms can set an extended deadline for their first independent evaluation based on their AUSTRAC account number.
AUSTRAC isn't expecting perfection
AUSTRAC has been clear: they recognise meaningful change doesn’t happen overnight. They’re not expecting perfection from day one. What they do expect is honest effort. That you’re genuinely working to meet your obligations and that you report suspicious activity when you see it.
If your firm has already been preparing, that work counts. The regulator has acknowledged the effort the industry has put in ahead of this date.
That said, enrolment is non-negotiable and the 29 July 2026 deadline is firm. Getting your firm enrolled and your foundations in place now is the right call. Even if you’re still building out your full compliance program.
Free resources from AUSTRAC
AUSTRAC has invested in practical guidance specifically for smaller businesses and professional services firms. These are all free:
- Program starter kits: co-designed with industry to help typical small firms get compliant
- AML/CTF essentials checklist: a step-by-step preparation guide
- AML/CTF obligations factsheet: a one-page summary of what you must do
- AML/CTF essentials webinar series: covering everything from the basics to outsourcing
These resources won’t do the compliance work for you, but they’re a solid starting point — especially for firms that are newer to this.
Webinar Series
BGL is running live webinars to help accounting firms get across their new AML/CTF obligations. These sessions are a great opportunity to ask questions and hear directly from the team.
Watch Webinar #1: BGL introduces you to AUSTRAC and Tranche 2
New to AML/CTF? This video is a great place to start. BGL walks through what AUSTRAC is, how Australia’s AML/CTF framework works and exactly how the Tranche 2 changes affect accountants and company and trust service providers.
Watch Webinar #2: BGL discusses Tranche 2 with Smart AML
Want to hear it straight from the experts? BGL sat down with the team at smartaml.com.au to talk through what the Tranche 2 changes mean for accounting firms, what’s changing, what to prioritise and how to get ready without the overwhelm.
Register for Webinar #3: How other firms are preparing for AML/CTF Requirements
Want to hear from experts in practice? This webinar will share practical experiences from accountants implementing AML/CTF requirements, followed by a live Q and A.
When: Tuesday 28 April 2026, 13:00 – 14:00 AEST
Register for Webinar #4: Introducing BGL Firm Verify
What tools do you need to manage AML/CTF compliance? This webinar will introduce you to BGL Firm Verify, a solution that brings together everything you need to comply with Tranche 2 into a single, simple, secure and audit-ready platform.
When: Tuesday 26 May 2026, 13:00 – 14:00 AEST
Let BGL Firm Verify handle the heavy lifting.
BGL Firm Verify is an AML/CTF compliance platform built specifically for Australian accounting firms navigating Tranche 2. It takes the complexity out of customer due diligence, risk assessment and reporting, so your team can stay focused on client work.
Questions? Talk to our team about how BGL Firm Verify works for firms like yours.
Further reading
Looking for more details on what Tranche 2 means for your firm? This earlier BGL article covers the key obligations and practical steps to take before 1 July 2026.
