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 preparing tax returns or assisting in a conveyance. 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 started running. The deadline itself runs 28 days from the day you become a reporting entity, which put it at 29 July 2026 for firms captured on commencement. 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.
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 | Within 28 days of becoming a reporting entity: 29 July 2026 for firms captured on commencement. Enrolment opened 31 March 2026; obligations started 1 July 2026 | AUSTRAC program starter kit policy documents; AUSTRAC’s published Tranche 2 timeline |
| What the form asks for | Your entity’s identity and identifiers, your contact details, and the designated services you provide | The enrolment form |
| 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 never assists in a conveyance and never creates or restructures a company or trust may provide no designated service at all, while a practice that does either is captured even if it happens once a year. Table 6 of the Act lists the professional services, and for law practices they are assisting in a conveyance, and creating or restructuring a company or trust. 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 form asks for, at the level AUSTRAC’s published material supports, falls into three categories. First, your entity: its legal name, the identifier it carries such as an ABN or ACN, and its business and contact details. Second, what you do: the designated services you provide. Third, who AUSTRAC can reach for compliance matters, which may be the person who runs your AML/CTF program. The exact fields are not published in a form we can verify, so we have not described a plausible form here: check the portal for the current fields before you rely on this description. The practical detail of enrolment sits in the AML/CTF Rules (2025).
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 your governing body, 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
Three mistakes cost firms time after enrolment, and each has a consequence you can name.
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 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 exact enrolment form and the post-enrolment process are the unsettled parts of this obligation. AUSTRAC’s published material settles the dates and who must enrol, but the precise fields on the form, whether it asks for your AMLCO’s name, and what AUSTRAC sends or expects after you enrol are not settled in a form we can verify. Treat the form in the portal as the current source of truth, and check AUSTRAC’s guidance before you describe the process to anyone else, because this part of the obligation is the one most likely to have changed since publication.
Where to start
If you have not enrolled, three steps get you there. If you have, run the same three steps as a review, because each of them is 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, its ABN or ACN, your contact details, and the designated services you will declare. 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. Enrolment is the obligation where the ongoing work is keeping the registration honest.
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.