Enrolment with AUSTRAC is a registration, not a compliance badge. It tells AUSTRAC who you are, which designated services you provide, and how to reach you, and every other Tranche 2 obligation, from your AML/CTF program to your reporting, sits on top of it.
You enrol because you provide a designated service. A designated service is a service the Act lists as carrying AML/CTF obligations, such as assisting in a conveyance or creating a company or trust for a client. Tax returns, BAS and bookkeeping on their own are not designated services. If you provide one, the Act treats you as a reporting entity, the term it uses for the entity that carries the obligations. Tranche 2 captured six sectors: accountants, legal practitioners, conveyancers, real estate agents, dealers in precious metals and stones, and trust and company service providers. The designated services page works through which services capture which sector, because capture follows the service, not the firm.
Enrolment opened on 31 March 2026, and the obligations started on 1 July 2026. The three months between them gave the new sectors time to register before the obligations applied. The deadline itself is set by s51B(1): you apply no later than 28 days after the day you start to provide a designated service. A transitional rule in the 2024 amending Act (Schedule 3, item 12) moved that deadline to 29 July 2026 for a firm that provided only Tranche 2 services (Table 2 item 2, Table 5 or Table 6) before 1 July 2026 and no other designated service. A firm that begins providing a designated service later counts its own 28 days from that day, because the requirement follows the service, not the calendar. A firm already enrolled for another designated service does not apply again (s51B(2)), and a firm that misses its deadline stays obliged to apply until it does (s51B(2B)).
Who enrols, when, and what it involves
The obligation has four parts: who enrols, when, what the form collects, and what happens after. The table sets them out, and the paragraphs below expand the parts that need detail.
| Question | Answer | Source |
|---|---|---|
| Who must enrol | Any entity that provides a designated service: accountants, legal practitioners, conveyancers, real estate agents, dealers in precious metals and stones, and trust and company service providers | The Act’s tables of designated services, including Table 6 for professional services |
| When | No later than 28 days after you start to provide a designated service. A firm that provided only Tranche 2 services before 1 July 2026, and no other designated service, had until 29 July 2026. Enrolment opened 31 March 2026; obligations started 1 July 2026 | The AML/CTF Act 2006 (Cth) s51B(1); the 2024 amending Act, Schedule 3 item 12; AUSTRAC’s published Tranche 2 timeline |
| What the form asks for | Your designated services, your entity’s identity, identifiers and contact details, your beneficial owners, size and turnover, and for a company its directors | AML/CTF Rules 2025, Rules 3-2 to 3-5 |
| What happens after | You are on the AUSTRAC roll; the obligations apply from 1 July 2026; you keep your enrolment details current | The AML/CTF Act 2006 (Cth); AUSTRAC’s published guidance |
The requirement to enrol attaches to the service, not to a profession label. A legal practice that provides none of the Table 6 services may provide no designated service at all, while a practice that provides any of them is captured even if it happens once a year. Table 6 of the Act lists the professional services and is not limited by profession: for law practices the common ones are assisting in a conveyance (item 1), helping a client buy or sell a company or trust (item 2), holding or managing a client’s money for a transaction (item 3, subject to s 6(5C)), and creating or restructuring a company or trust (item 6). The other sectors’ services sit in the other tables of the Act, and the question that decides enrolment is the same everywhere: whether you provide a listed service.
The entity that enrols can also surprise you. The reporting entity is the entity that provides the service, which is usually the firm, but where a practice runs services through a separate trust or company, the entity that carries the enrolment may not be the brand you trade under. The names that matter are the legal ones: the entity’s registered name and identifiers, not the trading name you print on invoices. Work out the legal entity behind each designated service before you enrol, because the enrolment names a specific entity, and it is that entity AUSTRAC holds the obligations against.
Enrolment itself is not new to the regime. Banks, credit unions, remittance providers, gambling businesses and bullion dealers have enrolled and reported for years under the earlier phases of the AML/CTF Act, and the change in 2026 is that professional services firms joined that roll. The enrolment mechanism for the new sectors is the same AUSTRAC online services process.
What the application must contain is set out in the AML/CTF Rules 2025 (Rules 3-2 to 3-5, made for s51E(2)(b) of the Act). First, what you do: a description of each kind of designated service, the date you started or plan to start, whether you provide it through an Australian permanent establishment, and your industry. Second, your entity: its full name and any other names it trades under, its ABN, ACN, ARBN or ARSN, any legal entity identifier, its registered office and principal place of business, its legal form, phone number, email address, the website domains you provide services through, and a description of its principal activity. Third, the people and size of the business: the names and dates of birth of any beneficial owners, the number of employees, whether it was a small business entity for tax purposes last year, any industry associations it belongs to, and its approximate annual turnover. A company also gives each director’s full name, former names and date of birth, director IDs, and its ultimate holding company if it has one; partnerships and trusts give details of their partners or trustees. Last, the person completing the form gives their name, role and contact details and declares the information true and correct, and you name a contact person for AUSTRAC’s industry contribution levy. The Rules do not list the AMLCO in the enrolment content: notifying AUSTRAC of your AMLCO is a separate duty, due within 14 days of appointing them (s26M(1)). For a firm that provided only Tranche 2 services before 1 July 2026, and no other designated service, the notice is on time if AUSTRAC receives it by the later of 14 days after the firm’s name is entered on the Reporting Entities Roll and 29 July 2026 (AML/CTF Transitional Rules 2026, s 19).
What happens after enrolment is where the real work starts. From 1 July 2026 the obligations apply in full: an AML/CTF program approved by a senior manager, customer due diligence before you provide a designated service, reporting to AUSTRAC, and seven years of records. The record-keeping obligation runs alongside, covering the customer due diligence you perform and the reports you lodge. You also need a named AML/CTF compliance officer (AMLCO), the person responsible for the program day to day, and the record of who that is belongs in your program rather than in a conversation. Enrolment itself does none of that work. It registers you, and everything above sits on top. The AML/CTF program page sets out what the program must contain, because that is the work enrolment points towards.
What catches people out
The first is treating enrolment as the finish line. Enrolment puts your entity on AUSTRAC’s roll; it does not satisfy the requirement to have an approved AML/CTF program, to run customer due diligence, or to report. A firm that stopped at enrolment reached 1 July 2026 registered but unprepared, with the obligations running and no machinery under them. The consequence is a reporting entity with no program, no customer due diligence process and no reporting discipline, and that state does not improve on its own.
The second is reading the enrolment dates into the reporting clocks. Enrolment starts no clocks and stops none, and the deadlines that matter run from their own triggers. The suspicious matter report (SMR), filed when you form a suspicion about a customer, is due within three business days of the suspicion forming, or 24 hours if it relates to terrorism financing, under s41(2). The threshold transaction report (TTR), for cash of $10,000 or more, is due within ten business days of the transaction under s43(2). Neither deadline moves because of when you enrolled. The consequence is an SMR filed after its deadline, and a late report is not fixed by anything you do with your enrolment later.
The third is letting the enrolment go stale. The record AUSTRAC holds covers your legal name, your contact details and the designated services you provide, and you are required to keep that record accurate rather than to fill it in once. Firms forget in ordinary ways: an office moves, a partner leaves, the practice adds conveyancing work it never declared. The consequence is that AUSTRAC’s correspondence goes to the wrong address, the services you actually provide stop matching your enrolment, and the divergence sits in the record a reviewer reads first.
What is still unsettled
The content of the application is settled by the Rules; the process around it is less so. How AUSTRAC’s online form presents those questions, and what AUSTRAC sends or expects after you enrol, are matters of AUSTRAC practice rather than law, and they can change. Check AUSTRAC’s guidance and the portal before you describe the process to anyone else.
Where to start
If you have not enrolled, these steps get you there. If you have, run them as a review, because each is a point where firms drift.
- Confirm the designated services: decide which services you actually provide against the tables of the Act, and which legal entity provides each one. Capture follows the service, and every step after this depends on the list being right.
- Gather what the form will ask for: your entity’s legal name and identifiers, addresses and contact details, the designated services you will declare, your beneficial owners’ names and dates of birth, staff numbers and approximate turnover, and for a company each director’s details and director ID. Keep that list next to the name of the person who can answer for compliance matters.
- Enrol, then diarise the review: complete the enrolment through AUSTRAC’s online services portal, and put a recurring check in your calendar for the enrolment itself: services added, people changed, addresses moved. For enrolment, the ongoing work is keeping the registration accurate.
How duely handles this
duely records your enrolment details, the AUSTRAC reporting entity number, the contact address and the enrolment date, and surfaces them where the program and the evidence pack need them. One limitation is worth stating plainly: those fields are captured, not validated. duely does not check them live against the Australian Business Register or AUSTRAC’s reporting entity register, so a typo in your reporting entity number will sit there until someone notices. The compliance calendar tracks the dated obligations that follow enrolment.