Industry guide
Accountants
Tax agents, BAS agents and bookkeepers performing designated services — such as setting up companies or trusts, or handling client funds — fall under AUSTRAC Tranche 2 from 1 July 2026.
Key obligations
Identify when you are providing a designated service
Forming companies, acting as a trustee, or managing client money triggers AML obligations — routine tax returns generally do not.
Enrol with AUSTRAC
AUSTRAC enrolment is open now — register as soon as possible if you provide any designated service. Obligations commence 1 July 2026.
Adopt an AML/CTF program
Document risk-based procedures for client onboarding, monitoring and reporting.
Conduct CDD on entity clients
Verify identity of the entity, its directors and beneficial owners.
Keep records for 7 years
All KYC records, transaction details and SMRs must be retained for at least 7 years.
Common pitfalls
Assuming all accountants are exempt
Tax compliance is generally out of scope, but company formation and trust services are not.
Relying on the ATO TFN check
AUSTRAC requires its own KYC standards — a TFN is not identity verification.
Outsourcing without oversight
You remain liable for KYC even if you use a third-party verification provider.
Frequently asked questions
Do tax-only accountants need to enrol?
If you only provide tax compliance and no designated services, you are not a reporting entity. Most full-service firms will be in scope.
Does my BAS-only practice need a program?
BAS agent work alone is generally out of scope, but check carefully if you also handle client trust money.
Not sure where you stand?
Take our free 3-minute Tranche 2 readiness quiz to get a personalised risk score and next-step roadmap for your business.