The AML/CTF Tranche 2 reforms are not a future problem — the key deadlines are here. With enrolment opening 31 March 2026 and full obligations commencing 1 July 2026, accounting firms that haven't started preparing are already behind.
This article sets out every deadline you need to know, in plain English, with a clear action for each one.
31 March 2026 — Enrolment with AUSTRAC opens. You can create your account and begin the process from this date.
1 July 2026 — Obligations formally commence. You must have your AML/CTF program in place and be conducting CDD on all clients receiving designated services.
29 July 2026 — Final deadline to complete enrolment if you were providing designated services on 1 July 2026.
The Full Timeline
Your Pre-1 July Checklist
Use this checklist to make sure you are ready before obligations commence:
- Confirm which of your services are designated services under the AML/CTF Act
- Create your AUSTRAC Online account from 31 March 2026
- Complete the AUSTRAC Business Profile Form (enrolment)
- Appoint an AML/CTF Compliance Officer and notify AUSTRAC by 29 July 2026
- Download and customise the AUSTRAC Accounting Program Starter Kit
- Complete your firm-level ML/TF/PF risk assessment
- Get your AML/CTF program approved by a senior manager
- Train all relevant staff on AML/CTF obligations before 1 July
- Set up your customer due diligence process for all clients receiving designated services
- Establish your record keeping system — records must be retained for 7 years
"AUSTRAC expects that by 1 July 2026 you will be enrolled, have an AML/CTF program in place, and have commenced customer due diligence on your clients."
Quick Reference: Key Dates at a Glance
| Date | Milestone | What You Need to Do |
|---|---|---|
| 31 Mar 2026 | Enrolment opens | Create AUSTRAC Online account, begin Business Profile Form |
| Before 1 Jul 2026 | Program deadline | Complete, approve and implement your AML/CTF program. Train all staff. |
| 1 Jul 2026 | Obligations commence | Be fully compliant. CDD required for all clients from this date. |
| 29 Jul 2026 | Enrolment deadline | Complete enrolment. Notify AUSTRAC of your Compliance Officer. |
| Annual | Compliance report | Submit annual AML/CTF compliance report to AUSTRAC. |
| Every 3 years | Independent evaluation | Have your AML/CTF program independently evaluated. |
Don't wait until June. With tens of thousands of firms expected to enrol, AUSTRAC's portal will be under significant demand in the weeks approaching the deadline. Starting early also gives you time to train staff and embed your CDD process before obligations kick in.
What Happens If You Miss the Deadlines?
Failing to enrol or operating without an AML/CTF program is a breach of the AML/CTF Act. AUSTRAC has significantly increased its enforcement activity in recent years and has been explicit that the obligations apply equally to small firms. Penalties for serious or repeated non-compliance can reach into the millions of dollars.
That said, AUSTRAC has also been clear that its initial approach to newly regulated Tranche 2 entities will be education-focused — provided firms are making genuine, documented efforts to comply. The worst position to be in is having done nothing at all.
For more detail on the full range of penalties and what triggers enforcement action, see our article: AML/CTF Penalties for Accountants — What Happens If You Don't Comply?
Further Reading
If you are working through your obligations step by step, these articles cover the key topics in more detail:
- Do I Need to Register with AUSTRAC? A Guide for Australian Accountants
- What is an AML/CTF Program and How Do I Write One?
- What is Customer Due Diligence (CDD) and How Does It Apply to Accountants?
Don't leave it until July.
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