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Tranche 2 guide

Am I captured? Designated services under Tranche 2

A designated service is the trigger for Tranche 2. Provide one and you are a reporting entity, with the main obligations applying from 1 July 2026.

By the duely Compliance Team

The AML/CTF Act 2006 (Cth) captures services, not professions. Six sectors came under the main obligations on 1 July 2026: accountants, legal practitioners, conveyancers, real estate agents, dealers in precious metals and stones, and trust and company service providers. Within each sector the same test applies: whether the work you do matches a service the Act lists as designated.

A designated service is a service the Act lists as one the regime regulates. The lists sit in the tables to s6 of the Act. Table 6, inserted by s 6(5B), covers the professional services: the conveyancing, company and trust work that captures the professions. Real estate agency work sits in Table 5, and precious metals and stones in Table 2. Provide one of those services in the course of carrying on a business and you become a reporting entity, the person the Act holds responsible for enrolment, an AML/CTF program (the documented set of policies and procedures each reporting entity must have), customer due diligence and reporting. Enrolment opened 31 March 2026, and obligations started on 1 July 2026.

The rest of this page maps each sector to the services that capture it. Find your profession, find your work, and check it against the table below.

The six sectors and the services that capture them

Each row names the services that capture a sector and where those services sit in the Act. The item numbers in the tables matter when you scope your program, and they are flagged for verification at the end of this page.

SectorServices that capture youWhere the service sits in the Act
Legal practitionersConveyancing; buying or selling a company or trust; holding client money for a transaction; company and trust workTable 6, s 6(5B), items 1, 2, 3 (subject to s 6(5C)) and 6, and any other Table 6 item you provide
AccountantsCompany and trust work; buying or selling a company or trust; arranging equity or debt financing for a company or trust; holding or managing a client’s money as part of their transactionTable 6, s 6(5B), items 2, 3, 4 and 6 (item 3 subject to s 6(5C)), and any other Table 6 item you provide
ConveyancersAssisting in a conveyanceTable 6, s 6(5B), item 1
Real estate agentsBrokering the sale, purchase or transfer of real estate; selling or transferring real estateTable 5 (real estate services), not Table 6
Trust and company service providersSelling shelf companies; creating or restructuring companies and trusts; acting as or arranging a trustee, director, secretary or nominee shareholder; providing a registered office or principal place of business addressTable 6, s 6(5B), items 5 to 9
Dealers in precious metals and stonesBuying or selling precious metals, stones or products (including jewellery) for $10,000 or more in physical currency or virtual assets; bullion dealing as a businessTable 2, items 2 and 1

If any service in a row describes work you do, that service is captured. You do not need to provide all of them, and you do not need to provide the service often. One conveyance a year makes the service captured; the rest of your work is a separate question.

Two services anchor the legal row: assisting in a conveyance (item 1), and creating or restructuring a company or trust (item 6). Helping a client buy or sell a company or trust (item 2) and holding client money for a transaction (item 3, subject to s 6(5C)) are also common. Do any of them and the main obligations apply to that work from 1 July 2026, whether you are a sole practitioner or a national firm. The full list of legal practice services sits in Table 6 of the Act.

Accountants: company, trust and client money work

The accounting services cover company and trust work: creating or restructuring a company or trust for a client (Table 6 item 6), helping a client buy or sell a company or other body corporate, or a legal arrangement such as a trust (item 2), and helping a client organise, plan or carry out equity or debt financing for a company or trust, including one not yet formed (item 4). Receiving, holding or managing a client’s money is captured only when it is part of assisting the client in the planning or execution of a transaction, or acting for them in one (Table 6 item 3), and not in the circumstances s 6(5C) excludes, such as money held as payment for your own fees. Table 6 is not limited by profession, so an accountant who sells shelf companies, acts as a director or nominee for a client, or provides a registered office address is captured for that work too (items 5, 7, 8 and 9). Work that matches no item in the tables to s6 does not capture you. Routine bookkeeping, tax returns, BAS work and preparing financial statements for an existing business, for example, are not designated services on their own. The capture follows the listed service, not your professional registration.

Conveyancers: the transfer of real property

Conveyancers are captured through the conveyancing service itself: assisting in a conveyance, which means preparing, executing and settling the transfer of real property for a buyer or seller. The service is defined by the work, not by the licence you hold. You are captured whether you call yourself a conveyancer or a law firm.

Real estate agents: sales, purchases and deposits

The real estate services are brokering the sale, purchase or transfer of real estate for a buyer, seller, transferee or transferor (Table 5 item 1), and selling or transferring real estate in the course of a business selling real estate where no independent agent brokers the sale (item 2). For a brokered sale, both the seller and the buyer are customers of the service. Holding the deposit while you broker the sale is part of the brokering service rather than a separate designated service, because the money-handling item in Table 6 does not apply where the service is another designated service (s 6(5C)(e)).

Trust and company service providers: formation, trusteeship and nominees

The trust and company services cover selling or transferring shelf companies (Table 6 item 5), creating and restructuring companies and trusts (item 6), acting as or arranging for someone to act as a director, company secretary, partner or trustee, or as a power of attorney of a company or trust, on a client’s behalf (item 7) or as a nominee shareholder (item 8), and providing a registered office or principal place of business address (item 9). Much of this work was already performed by accountants and lawyers; the reforms capture it as a service in its own right. You are captured for that work whether you are a trust company, an accountant or a law firm.

Dealers in precious metals and stones: the trade itself

The dealers’ service is set by the Act. Buying or selling precious metal, precious stones or precious products in the course of a business is a designated service where the purchase involves $10,000 or more in physical currency or virtual assets, counting transactions that are linked or appear to be linked (Table 2 item 2). Precious products include jewellery, watches, other objects of personal adornment and goldsmiths’ or silversmiths’ wares that contain precious metal or stones (s 5A(6)). Sales paid by card or bank transfer do not count towards the threshold. Buying or selling bullion as part of a bullion-dealing business is captured with no cash threshold (item 1).

Each table in s6 names the customer of the designated service: for brokering a property sale, both the seller and the buyer; for most professional services, the person you act for. That customer is who you identify and verify, and who you report on if a suspicion forms.

Two consequences follow from the service-based shape. The first is scoping: your practice can be captured for one line of work and outside for another, so your list of services is your first compliance document. The second is the program: the AML/CTF program you build has to cover the services you actually provide, not your profession’s whole range.

What catches people out

Occasional provision still captures you. The Act sets no minimum volume and no frequency test. If you provide a designated service, you are a reporting entity for it, whether you do it daily or once a year. If you assume a one-off transaction sits outside the regime, you still carry the full set of obligations for that service: enrolment, a program, verification of the customer, and reporting if a suspicion forms. Get this wrong and you operate a captured service with no program behind it, and every file you touch in that service is outside the regime’s controls.

Part of the practice can be in scope while the rest is not. Your conveyancing work can be captured while your commercial litigation sits outside. Your company and trust work can be captured while other lines of work do not appear in the tables at all. If you decide capture at firm level, you get one of two failures: you treat everything as captured and build compliance load you do not need, or you treat nothing as captured and miss the service that is in scope. Run the analysis service by service, and write the result down, because enrolment and the program both depend on it.

The court-order exclusion is narrow, and it needs evidence. Some services fall outside the tables where the transaction results from a court order. The exclusion attaches to that transaction, not to the customer and not to the service generally. A customer who was once on the receiving end of a court-ordered transaction is still a customer for every other service they ask you to provide. Treat the exclusion as a standing status and you leave captured transactions outside the regime, with no verification and no reporting. Treat the service as captured and record the court order on the file before treating anything as excluded.

What is still unsettled

How the new services apply in practice is still settling. The AML/CTF Rules (2025) and AUSTRAC’s sector guidance are working through the detail: what counts as providing a particular service, where the edges of a service sit, and how the new items interact with services that were already regulated. The table and item numbering in s6 is worth confirming against the current version of the Act before you rely on it. The trigger itself is not unsettled. If you provide a listed service, you are a reporting entity for it (from 31 March 2026 at the earliest), and the main obligations apply from 1 July 2026 or, if later, from when you start. What is settling is how precisely you can scope the edges. Write your scope now, version it, and expect to revise it.

Where to start

If you have not done this yet, start here:

  1. List every service you provide: write down what the firm actually does, line by line, not by profession. Match each line against this page’s table and the tables in the Act. Where a line matches, that service is captured. Where it does not, note why, so your scope decision is recorded.
  2. Enrol the reporting entity: enrolment with AUSTRAC opened 31 March 2026, ahead of the 1 July 2026 commencement. The enrolment guide covers who has to enrol and what the form asks for.
  3. Build the program around the services you found: your AML/CTF program has to reflect the services you actually provide, which is why step one comes first. The program guide sets out what a program must contain and who approves it.

How duely handles this

Whether a firm is captured is not a global setting in duely. Each engagement carries a scoping decision that records which designated service is being provided, and the obligations that follow attach to that decision. The service catalogue is per-vertical, so an accounting firm and a conveyancer see different lists, and a firm that provides a captured service occasionally is handled the same way as one that provides it daily.

Common questions

Is my firm captured by Tranche 2?
Capture depends on the services you provide, not on your profession. If you provide a service the Act lists as designated, you are a reporting entity, even if you provide it rarely. For Tranche 2 services that status started on 31 March 2026, and the main obligations applied from 1 July 2026. The six sectors are accountants, legal practitioners, conveyancers, real estate agents, dealers in precious metals and stones, and trust and company service providers.
What is a designated service under the AML/CTF Act?
A designated service is a service the Act lists as one the regime regulates. The lists sit in the tables to s6 of the AML/CTF Act 2006 (Cth), with Table 6 (inserted by s 6(5B)) covering the professional services, Table 5 covering real estate services and Table 2 covering precious metals and stones. Provide one in the course of carrying on a business and you become a reporting entity with enrolment, program and reporting obligations.
I only do one conveyance a year. Am I still captured?
Yes. The Act captures the service, not the volume. If you provide a designated service, you are a reporting entity for it, whether you do it once a year or every day. The obligations attach from that service, including enrolment, an AML/CTF program, identifying and verifying your client, and reporting if a suspicion forms.
Which sectors does Tranche 2 capture?
Six: accountants, legal practitioners, conveyancers, real estate agents, dealers in precious metals and stones, and trust and company service providers. Each is captured only to the extent it provides a designated service, so part of a practice can be in scope while the rest is not. Obligations started on 1 July 2026, with enrolment open from 31 March 2026.
Does a court order exempt my firm from AML/CTF obligations?
Only for the transaction the order produces. Some services are excluded where the transaction results from a court order, but the exclusion attaches to that transaction, not to the client or the service generally. Every other service you provide stays captured, so treat the service as captured and record the court order on the file.

Where this happens in duely

This is the obligation above on a product screen, with sample data.

See the engagement workflow
The duely review screen for a new engagement, showing the customer with their due diligence attached automatically and the designated services chosen.

This is one obligation of many

Take the 2-minute readiness assessment to see the full set that applies to your firm, or book a walkthrough and watch one engagement run from scoping to a finished evidence pack.