By Joshua Occhino, Co-founder, Ezyiah
Short answer: Yes. AML/CTF obligations have applied to accountants who provide designated services since 1 July 2026, and those firms had to enrol with AUSTRAC within 28 days (by 29 July 2026). If your firm forms companies or trusts, acts as or arranges nominee directors, trustees or shareholders, or handles client money beyond ordinary fee collection, you are likely a reporting entity. You need an AML/CTF program, customer due diligence and suspicious matter reporting. Firms that haven't enrolled should do it now: late enrolment is itself a breach.
Where do things stand now?
- Obligations started on 1 July 2026 for tranche 2 entities, including accountants providing professional designated services.
- Enrolment was due within 28 days of providing a designated service, so by 29 July 2026 for firms already providing them. AUSTRAC reported 62,710 businesses enrolled as at 20 October 2026. See enrol with AUSTRAC.
- Enrolment details must be kept up to date. Changes are due within 14 days.
- The first annual compliance report covers 2026–27 and is lodged between 1 July and 30 September 2027. AUSTRAC has said it isn't expecting perfection from newly regulated entities in the first year, but it does expect genuine effort.
Which services bring a firm into scope?
Scope depends on what you do, not your size. AUSTRAC's guidance for accountants covers services such as:
- forming companies, trusts and other legal arrangements
- acting as, or arranging for someone to act as, a nominee director, trustee, partner or shareholder
- receiving, holding or managing client money or assets outside ordinary fee arrangements
- assisting with buying or selling businesses or real estate
Routine tax return preparation, BAS lodgement and bookkeeping, with no designated service involved, don't on their own make a firm a reporting entity. One designated service is enough, though.
What does a firm need to have in place?
AUSTRAC's summary of obligations for tranche 2 entities includes:
- An AML/CTF program, including a risk assessment specific to the firm, approved by senior management. AUSTRAC's Accounting Program Starter Kit is designed for smaller practices.
- An AML/CTF compliance officer.
- Customer due diligence before providing a designated service, plus ongoing monitoring.
- Reporting:
- suspicious matter reports within 24 hours for terrorism financing, or within 3 business days otherwise
- threshold transaction reports for physical currency of $10,000 or more, within 10 business days
- Staff training and record keeping.
What should a firm that hasn't acted do now?
- Map your services against AUSTRAC's designated services list.
- If you're in scope, enrol immediately, and record why you were late.
- Adopt the Starter Kit (if eligible), complete the risk assessment and appoint a compliance officer.
- Apply customer due diligence to new designated-service engagements now, and plan how to cover existing clients.
- Put the 2027 compliance report in the firm calendar.
How Ezyiah helps
Ezyiah isn't AML/CTF software. It doesn't do customer due diligence or reporting. As an AI bookkeeper with its own ledger, it keeps clients' books current from live bank feeds, with team invites and activity logs showing who did what in each client file. That supports the good record-keeping habits a compliance program relies on. Your firm keeps its AML/CTF program and its sign-off.
See Ezyiah for accounting firms.
Frequently asked questions
When did AML/CTF obligations start for accountants?
On 1 July 2026, for accountants providing designated services.
What was the AUSTRAC enrolment deadline?
Within 28 days of first providing a designated service. That was 29 July 2026 for firms already providing them on 1 July.
Does BAS or tax return work alone trigger AML/CTF obligations?
Not on its own. Designated services such as company or trust formation, nominee arrangements or handling client funds do.
When is the first AML/CTF compliance report due?
Between 1 July and 30 September 2027, covering 2026–27.
