The AML/CTF Tranche 2 reforms are not a future problem — the key deadlines are here. With enrolment opening 31 March 2026 and full obligations commencing 1 July 2026, accounting firms that haven't started preparing are already behind.

This article sets out every deadline you need to know, in plain English, with a clear action for each one.

The Three Dates That Matter

31 March 2026 — Enrolment with AUSTRAC opens. You can create your account and begin the process from this date.

1 July 2026 — Obligations formally commence. You must have your AML/CTF program in place and be conducting CDD on all clients receiving designated services.

29 July 2026 — Final deadline to complete enrolment if you were providing designated services on 1 July 2026.

The Full Timeline

Dec 2024
Already happened
AML/CTF Amendment Act Receives Royal Assent
On 10 December 2024, the AML/CTF Amendment Act was signed into law, formally extending AML/CTF obligations to accountants, bookeekpers and other Tranche 2 professions for the first time.
31 Mar 2026
Now open
Enrolment Opens for Tranche 2 Entities
AUSTRAC's enrolment portal opens for accountants and other Tranche 2 entities. You can create your AUSTRAC Online account, complete the Business Profile Form, and nominate your AML/CTF Compliance Officer from this date. You cannot enrol before this date.
Before 1 Jul 2026
Action required now
Complete Your AML/CTF Program
Your AML/CTF program must be completed and approved by a senior manager before you provide your first designated service from 1 July 2026. AUSTRAC's free Accounting Starter Kit provides a customisable framework. Allow 2–4 weeks minimum to complete, train staff, and get sign-off.
1 Jul 2026
Key deadline
AML/CTF Obligations Commence
From this date, all accounting firms providing designated services must be fully compliant. This means your AML/CTF program is in place, your staff are trained, and you are conducting customer due diligence on every client receiving designated services. Providing designated services without a program in place is a breach of the AML/CTF Act.
29 Jul 2026
Enrolment deadline
Final Enrolment Deadline
All firms providing designated services on 1 July 2026 must be enrolled with AUSTRAC by this date — 28 days after obligations commence. Firms that begin providing designated services after 1 July must enrol within 28 days of starting. Your AML/CTF Compliance Officer must also be notified to AUSTRAC by this date.
Ongoing
Ongoing obligations
Annual Compliance Report
Every year, reporting entities must submit an annual AML/CTF compliance report to AUSTRAC summarising how they met their obligations during the previous year. AUSTRAC will contact you when it is time to complete this report.
Every 3 years
Ongoing obligations
Independent Program Evaluation
Your AML/CTF program must be independently evaluated at least once every three years. For newly enrolled firms, the first evaluation deadline will be set by AUSTRAC based on your account number — and will be no less than three years from 1 July 2026.

Your Pre-1 July Checklist

Use this checklist to make sure you are ready before obligations commence:

"AUSTRAC expects that by 1 July 2026 you will be enrolled, have an AML/CTF program in place, and have commenced customer due diligence on your clients."

Quick Reference: Key Dates at a Glance

Date Milestone What You Need to Do
31 Mar 2026 Enrolment opens Create AUSTRAC Online account, begin Business Profile Form
Before 1 Jul 2026 Program deadline Complete, approve and implement your AML/CTF program. Train all staff.
1 Jul 2026 Obligations commence Be fully compliant. CDD required for all clients from this date.
29 Jul 2026 Enrolment deadline Complete enrolment. Notify AUSTRAC of your Compliance Officer.
Annual Compliance report Submit annual AML/CTF compliance report to AUSTRAC.
Every 3 years Independent evaluation Have your AML/CTF program independently evaluated.

Don't wait until June. With tens of thousands of firms expected to enrol, AUSTRAC's portal will be under significant demand in the weeks approaching the deadline. Starting early also gives you time to train staff and embed your CDD process before obligations kick in.

What Happens If You Miss the Deadlines?

Failing to enrol or operating without an AML/CTF program is a breach of the AML/CTF Act. AUSTRAC has significantly increased its enforcement activity in recent years and has been explicit that the obligations apply equally to small firms. Penalties for serious or repeated non-compliance can reach into the millions of dollars.

That said, AUSTRAC has also been clear that its initial approach to newly regulated Tranche 2 entities will be education-focused — provided firms are making genuine, documented efforts to comply. The worst position to be in is having done nothing at all.

For more detail on the full range of penalties and what triggers enforcement action, see our article: AML/CTF Penalties for Accountants — What Happens If You Don't Comply?

Further Reading

If you are working through your obligations step by step, these articles cover the key topics in more detail:

Don't leave it until July.

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