Tranche 2 has been live since 1 July 2026.
Roughly 90,000 firms are now reporting entities.
The AML/CTF Amendment Act 2024 (Cth) extends the reporting-entity regime to accountants, law firms, real estate agents, trust and company service providers, and precious metals dealers. The scope is services-based, not profession-wide. This is what captures each profession, what the five core obligations are, and how Ironbark fits the verification component.
Lawyers, accountants, real estate agents, trust and company service providers, and precious metals dealers are already covered. If your program is not written, the obligation is already running, not approaching. Ironbark checks ABNs against AUSTRAC, ASIC, ABR, and DFAT sanctions in seconds.
If the deadline has already passed you
- 7 things that became true when Tranche 2 started, written for practices that are already inside the regime rather than preparing to enter it.
- You are liable for a counter-party you never checked, on why the obligation does not end at onboarding.
Profession guides
Each guide covers what is in scope, the five obligations, and how Ironbark fits.
what accountants need to do now it is in force.
Read the guide →AML compliance guide for law firms.
Read the guide →AML guide for real estate agents.
Read the guide →The five obligations, in order
- 1Enrol with AUSTRAC
A business providing a designated service on 1 July 2026 had until 29 July 2026, and that deadline has passed. A later starter has 28 days from starting. Enrol now if you have not.
- 2AML/CTF program
Part A risk assessment plus Part B customer due diligence procedures.
- 3Appoint an AMLCO
An employee or partner at management level. Cannot be outsourced.
- 4Run CDD
Identify and verify customer before service. Enhanced DD for higher-risk.
- 5Report and retain
SMRs, TTRs (AUD 10,000+), record-keeping for seven years.
FAQ
When does AUSTRAC Tranche 2 commence?
1 July 2026. The AML/CTF Amendment Act 2024 (Cth) passed Parliament in November 2024 and extends the reporting-entity regime under the AML/CTF Act 2006 (Cth) to accountants, law firms, real estate agents, trust and company service providers, and precious metals dealers on that date.
Who is captured by Tranche 2?
Roughly 90,000 Australian businesses: approximately 36,717 accountants and tax agents, about 36,700 lawyers (78% in sole or small practice), 45,440 real estate agencies, plus trust and company service providers and precious metals dealers. The capture is services-based: an entity is a reporting entity only in respect of the designated services it provides.
When did AUSTRAC enrolment open?
31 March 2026. A business already providing a designated service on 1 July 2026 had until 29 July 2026 to enrol, and that deadline has passed. A business that starts providing a designated service later must apply to enrol within 28 days of starting. Enrolment is via AUSTRAC Online. If you were captured on 1 July and have not enrolled, AUSTRAC's published position is that enrolment is still required, and on 28 August 2026 it began issuing notices to businesses that appear to be providing designated services without having enrolled.
What are the five core obligations?
Enrol with AUSTRAC; adopt an AML/CTF program (Part A risk assessment plus Part B customer due diligence); appoint an AML Compliance Officer; run customer identification and verification; report suspicious matter reports (SMRs) and threshold transaction reports (TTRs) of AUD 10,000 or more. Records are retained for seven years.
How does Ironbark help?
Ironbark is an AU-native compliance check product. In one check it verifies a customer entity against the Australian Business Register, the ASIC company and director registers, the ASIC banned-and-disqualified-persons register, the AUSTRAC reporting-entity and enforcement registers, the DFAT consolidated sanctions list, and the Federal Court of Australia. The report is a timestamped PDF plus JSON artefact for the reporting entity's seven-year record. $0.49 per check. Credits never expire.
Is Ironbark an end-to-end AML/CTF programme?
No. Ironbark discharges the verification component of customer due diligence. The AML/CTF program document, the AMLCO appointment, the SMR and TTR reporting workflow, and seven-year record-keeping remain the reporting entity's responsibility. Industry associations (CPA Australia, Law Societies, REIA branches) publish template programs and templates. Those plus Ironbark plus an AMLCO is the common minimum setup for a sole practice.
What is the AUD 10,000 threshold?
A threshold transaction is one involving the receipt, payment, or transfer of AUD 10,000 or more (or its foreign-currency equivalent) where the reporting entity is a party. Structured transactions (multiple transactions deliberately kept below the threshold) are also caught. A TTR must be lodged with AUSTRAC within 10 business days of the transaction.
Where can I read the legislation?
The primary instruments are the AML/CTF Act 2006 (Cth), the AML/CTF Rules Instrument 2007 (No. 1), and the AML/CTF Amendment Act 2024 (Cth). AUSTRAC publishes plain-language guidance and worked examples on its website. Industry associations (Law Council of Australia, CPA Australia, REIA) publish sector-specific commentary.
Run a free check
Ten checks per month on the free tier. $0.49 per check on PAYG. Credits never expire.
