When Does Tranche 2 Start? AUSTRAC Obligations for Accountants and Lawyers Explained

Australia's Tranche 2 AML/CTF reform brings accounting practices, law firms, real estate agents, and other professional services businesses under the same regulatory framework that has applied to banks and financial institutions since 2006. The commencement date is 1 July 2026.

For accounting practices and law firms specifically, this means that providing certain designated services after 1 July 2026 without an AML/CTF program in place is a breach of the Act — regardless of whether AUSTRAC has formally reviewed your practice. The obligations are self-executing: they apply on the date, not when AUSTRAC contacts you.

Tranche 2 covers accounting services including company formation, acting as a trustee or company director on behalf of clients, managing client money or accounts, and assisting with buying or selling real property. For legal practices, it covers similar activities plus conveyancing and certain trust-related legal work.

AUSTRAC enrolment must be completed within 28 days of 1 July 2026 — by 29 July 2026. The enrolment portal is already open. There is no practical reason to wait. Enrolment is a separate step from building your AML/CTF program and should be completed alongside it.

What must be in place by 1 July 2026: a written AML/CTF program (risk assessment, policy, procedures), a client due diligence workflow that staff can actually follow, a staff training program with documented completion, and — if you have existing clients for whom you provide designated services — an assessment of whether their files need updated due diligence.

The 'existing client' question catches many practices by surprise. If you have been providing designated services to existing clients before 1 July 2026, you will need a process for determining whether those client relationships need fresh CDD — particularly if identity was never formally verified under a structured process. AUSTRAC's guidance expects existing clients to be risk-assessed even where new onboarding CDD is not required.

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.