Enrolment closed on 29 July 2026. If your agency is not enrolled with AUSTRAC, the penalty clock is running daily and it does not stop until you enrol. The fix is still one session, still plain English. AUSTRAC has said it is targeting agencies that wilfully ignore the obligation. Acting now is what takes you out of that group.
Since the 29 July 2026 enrolment deadline
The Tranche 2 reforms pulled real estate into the AML/CTF Act. If your agency helps people buy, sell or transfer property, you are caught. Enrolment is still open, and enrolling late is far better than not enrolling.
AUSTRAC enrolment opened for newly regulated sectors. It is still open today.
Obligations commenced. From this date you needed a risk assessment, a written AML/CTF program, a compliance officer and trained staff.
The enrolment deadline. If you are not enrolled, a separate contravention now accrues for each day you keep providing services unenrolled.
Enrolling now does not undo the days already passed, but it stops the clock, and it is the single clearest way to show AUSTRAC you are not one of the agencies wilfully ignoring the obligation.
No compliance software to licence, no 120-page weekend. I sit with you, get the enrolment lodged, stand the whole program up, then hand you the folder. Late is fixable. Unenrolled is not a position you want to hold.
Optional. The setup sprint stands on its own and you are not signed up to anything by taking it.
Plain English, dead-right on the detail, and no lecture about the date you missed.
I've read the AML/CTF reforms end to end and built the setup on AUSTRAC's own framework, so you get exactly what the law requires. No jargon, no scare tactics, no guesswork. Done properly, done quickly, and off your plate.
Pete, Property Tax CompassPlain-English tools for Australian property and tax law.
AUSTRAC publishes free starter kits, and you can absolutely do this yourself if you have the time and a tolerance for legislation. What I sell is the shortcut: done properly, on time, by someone who speaks agent. If your setup is complicated, I'll tell you to see a specialist.
Yes. Since 1 July 2026, real estate and buyer's agents who broker the purchase, sale or transfer of property have been reporting entities under the AML/CTF Act 2006. AUSTRAC opened enrolment on 31 March 2026 and enrolment remains open. Businesses that begin providing designated services now must enrol within 28 days of starting.
The deadline was 29 July 2026, being 28 days after obligations commenced on 1 July 2026. It has passed, and no extension was offered. If you are still providing designated services without being enrolled, section 51B of the AML/CTF Act treats each day as a separate contravention, accruing until you enrol or stop providing those services. Enrolment is still open and you should complete it as a priority. Your AML/CTF compliance officer must also be notified to AUSTRAC.
Yes, you should still enrol, and promptly. AUSTRAC's published regulatory expectations state that it "does not expect perfection on day one" and that after 1 July 2026 it would focus enforcement in the newly regulated sectors on entities "who wilfully ignore the obligation to enrol" and those it suspects are complicit with or wilfully blind to money laundering. Enrolling late, and getting a genuine program in place, is the clearest evidence that you are not in either category. Staying unenrolled is what puts you there. This is general information, not legal advice, and if you have been trading unenrolled for some time it is worth speaking to a lawyer about your specific position.
No. Identity verification tools handle per-transaction checks such as KYC, document verification and sanctions screening. They do not fulfil your obligation to enrol with AUSTRAC, prepare a written AML/CTF program, complete a business-wide risk assessment, appoint a compliance officer or deliver ongoing staff training. Those requirements sit with your agency regardless of which verification tool you use.
At minimum: a risk assessment identifying your money laundering, terrorism financing and proliferation financing risks; Part A policies and procedures to manage and mitigate those risks; Part B customer due diligence procedures; a nominated AML/CTF compliance officer; and an ongoing employee training program with records. AUSTRAC publishes a free program starter kit for small real estate agencies, but you still need to tailor it to your business.
The Commonwealth penalty unit rose to $364 on 1 July 2026. Under section 51B of the AML/CTF Act, once you have provided designated services for 28 days without enrolling, a separate contravention accrues for each day you remain unenrolled, at up to 60 penalty units per day for a body corporate, which is $21,840 per day. For the most serious contraventions AUSTRAC can seek civil penalty orders through the Federal Court of up to 100,000 penalty units for a body corporate (up to $36.4 million) and up to 20,000 penalty units for an individual (up to $7.28 million). AUSTRAC can also issue infringement notices, accept enforceable undertakings and give remedial directions. Failing to enrol is specifically listed as an infringement notice offence. These are maximums set by the legislation, not a prediction of what any particular agency would face.
Tools like PEXA Clear are very good at the per transaction checks. They are not your AML/CTF program, and the law still puts the rest on your agency. Here is the split.
| What a verification tool handles | What the law still requires from your agency |
|---|---|
| Verifying a client's identity through ID and document checks | Enrolling your agency with AUSTRAC, which was due 29 July 2026 |
| KYC and KYB checks on buyers, sellers and entities | A written risk assessment of your whole business, not just one deal |
| Screening for sanctions, politically exposed persons and adverse media | A documented AML/CTF program (Part A policies and Part B customer due diligence) |
| Flagging the risk level on a single transaction | Appointing your AML/CTF compliance officer and setting out the role |
| An audit trail and prompts for suspicious matter reports | An ongoing staff training program and the records to prove it |
| The checks, deal by deal | Keeping the whole program current and audit ready over time |
A verification tool runs the checks. It does not write your program, enrol you, or appoint your compliance officer. That is the setup we handle, so whichever tool you choose has a compliant program sitting behind it.
General information only. This is not legal or financial advice. For advice on your agency's specific obligations, speak to a licensed professional.
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The enrolment deadline passed on 29 July 2026. This one-pager covers the 10 steps to get your agency enrolled and compliant now, in the order that matters.