Tranche 2 for Accountants: What Actually Changes on 1 July 2026

From 1 July 2026, many accounting services will be captured by expanded AML/CTF obligations. The biggest shift is operational: client checks become a mandatory system, not a discretionary process. If your firm helps with company setup, trust-related work, or client money activities, this is now core compliance work.

Your onboarding process must collect and verify identity details before designated services start. For individual clients, that means full legal name, date of birth, and residential address. For entities, firms need legal entity details and beneficial owner identification. Records must be accurate, traceable, and retrievable for review.

Risk assessment is not a one-time worksheet. AUSTRAC expects a risk-based approach that drives different levels of due diligence. Your controls should clearly explain what low, medium, and high-risk profiles look like and what escalation actions your staff must take.

Many practices will need to redesign internal handoffs. Front-office onboarding, partner review, and compliance oversight should be connected through one documented workflow. If evidence is scattered across inboxes and shared folders, response times and audit outcomes are likely to suffer.

Another early priority is clarifying exactly which services your firm delivers are designated services under the regime. This scoping exercise should be documented and reviewed by leadership, because over-scoping can create unnecessary friction while under-scoping leaves real exposure unmanaged. A simple service map tied to required controls gives teams practical clarity: when standard onboarding applies, when enhanced due diligence is mandatory, and when work should pause pending compliance review.

Need a practical way to handle AML/CTF client checks, risk scoring, and evidence capture? ClientCheck helps Australian firms run compliant onboarding workflows aligned with AUSTRAC expectations. Start with a walkthrough and see how your team can go live fast.