AML/CTF Compliance for Australian Accounting Firms in 2026


The Australian AML/CTF reforms are now approaching a firm deadline. From 1 July 2026, accounting firms providing services beyond tax return preparation will be brought under the AML/CTF regime, introducing new obligations around client onboarding, record-keeping, risk management, and reporting to AUSTRAC.

At NCSGX, we are helping Australian accounting firms prepare for these changes. This guide outlines who is impacted, the key compliance requirements, and the practical steps firms should take to achieve AML/CTF compliance before the deadline.

Are Accounting Firms Covered Under the New AML/CTF Reforms?

The answer is yes for many firms, but not simply because they are accounting practices.

The legislation does not regulate accountants as a profession. Instead, it applies to businesses that provide specific designated services. If your firm offers any of these services, even occasionally, you will likely fall within the scope of the reforms.

These designated services include:

  • Assisting clients with transactions involving the purchase, sale, or transfer of real estate or businesses
  • Managing client funds, accounts, securities, or other assets
  • Establishing, operating, or managing companies, trusts, or other legal arrangements
  • Acting as, or arranging for someone to act as, a director, company secretary, trustee, or nominee shareholder
  • Providing registered office services or business addresses for clients

Many full-service accounting firms routinely undertake activities such as company incorporations, trust establishment, SMSF administration, or holding client funds. These activities are enough to trigger AML/CTF obligations.

On the other hand, services such as income tax return preparation, BAS lodgements, and general bookkeeping, when performed in isolation, are not considered designated services.

The reality, however, is that very few accounting practices provide only tax compliance services. Even a single engagement involving trust setup or registered office services may bring a firm within the regulatory framework.

Why Are These Changes Happening Now?

Australia has long been viewed as an outlier among major economies for not extending AML/CTF regulations to professional "gatekeeper" industries such as accounting, legal services, and real estate.

For years, the global standard-setting body, the Financial Action Task Force (FATF), identified this as a significant gap in Australia's anti-money laundering framework.

The AML/CTF Amendment Act 2024 addresses this issue. The legislation was passed by Parliament on 29 November 2024 and received Royal Assent on 10 December 2024. Throughout 2025, supporting AML/CTF Rules and sector-specific guidance for Tranche 2 entities, including accounting firms, were finalised.

The rationale behind these reforms is straightforward. Criminal organisations often rely on professional advisers to establish entities, structure transactions, move funds, and create a veneer of legitimacy. By bringing accountants into the AML/CTF regime, regulators aim to introduce additional safeguards at these critical points.

Key AML/CTF Dates Every Accounting Firm Must Know

The implementation timeline is clear, and accounting firms should already be planning their compliance activities.

10 December 2024 – AML/CTF Amendment Act receives Royal Assent

31 March 2025 – Updated "tipping off" offences commence

31 March 2026 – Changes take effect for existing reporting entities and virtual asset service providers

1 July 2026 – AML/CTF obligations commence for Tranche 2 entities, including accounting firms

29 July 2026 – Deadline for newly regulated firms to complete AUSTRAC enrolment

The most significant dates for accounting firms are 1 July 2026, when obligations officially begin, and 29 July 2026, when enrolment with AUSTRAC must be completed.

Waiting until July to start preparations could create unnecessary pressure. Firms that begin implementing processes now will find compliance far more manageable.

Understanding Your AML/CTF Obligations

Once your firm is captured under the new regime, several obligations become mandatory.

1. Enrol with AUSTRAC

AUSTRAC enrolment is the first step. Firms will need to provide information regarding their business structure, designated services, and nominated compliance officer.

The enrolment deadline is 29 July 2026.

2. Appoint an AML/CTF Compliance Officer

Every captured firm must appoint an individual responsible for overseeing AML/CTF compliance.

For smaller practices, this responsibility often sits with a partner or senior leader who can ensure that policies and procedures are implemented effectively.

3. Conduct a Risk Assessment

Firms must understand their exposure to money laundering and terrorism financing risks.

This assessment should consider:

  • Types of clients served
  • Services provided
  • Geographic risk factors
  • Delivery channels and transaction methods

Understanding these risks forms the foundation of an effective compliance framework.

4. Develop and Maintain an AML/CTF Program

An AML/CTF program is a documented set of policies, procedures, and internal controls designed to manage identified risks.

The program should outline:

  • Client verification processes
  • Ongoing monitoring procedures
  • Staff training requirements
  • Record-keeping protocols
  • Escalation and reporting procedures

Importantly, this cannot be a document created simply to satisfy regulators. It must be practical, implemented, and embedded into everyday operations.

5. Carry Out Customer Due Diligence (CDD)

Customer Due Diligence requires firms to understand exactly who their clients are.

This includes:

  • Verifying client identities
  • Identifying beneficial owners
  • Understanding the purpose and nature of business relationships
  • Applying enhanced checks for higher-risk clients, including politically exposed persons (PEPs)

CDD is not a one-time onboarding exercise. Ongoing monitoring is also required throughout the client relationship.

6. Meet Reporting Obligations

Captured firms will have several reporting requirements, including:

Suspicious Matter Reports (SMRs): Lodged when there are reasonable grounds to suspect a client or transaction may involve criminal activity.

Threshold Transaction Reports (TTRs): Required for cash transactions of $10,000 or more.

Annual Compliance Reports: Submitted to AUSTRAC to demonstrate ongoing compliance with AML/CTF obligations.

7. Maintain Proper Records

Accounting firms must retain identity verification records, transaction information, and AML/CTF documentation for generally seven years.

Strong record-keeping processes will be essential for demonstrating compliance during regulatory reviews or audits.

How Accounting Firms Can Start Preparing Today

You don’t need to implement every requirement at once, but you do need to start preparing. A practical approach includes:

  • Determine whether your firm is in scope: Review your services against the designated services list. Firms that establish entities, manage client funds, or provide registered office services are likely to be captured.

  • Appoint an AML/CTF Compliance Officer: Assign clear ownership early to drive implementation and ongoing compliance.

  • Conduct a risk assessment: Evaluate your client base, service offerings, and areas of higher money laundering and terrorism financing risk.

  • Develop your AML/CTF program and CDD procedures: Establish practical client onboarding and verification processes that your team can consistently follow.

  • Track key deadlines: AML/CTF obligations commence on 1 July 2026, and AUSTRAC enrolment must be completed by 29 July 2026.

  • Train your team: Ensure client-facing and operational staff understand their responsibilities and know when to escalate potential issues.

If this feels overwhelming alongside EOFY responsibilities, you are not alone. With the right support, firms can manage the administrative burden efficiently and prepare for compliance with confidence.

Final Thoughts

The AML/CTF reforms for accountants come into effect on 1 July 2026, with AUSTRAC enrolment required by 29 July 2026. If your firm provides designated services such as establishing entities, managing client funds, or acting as a registered office, you will be required to implement a compliant AML/CTF program before the deadline.

Firms that begin preparing now will be better positioned to achieve AML/CTF compliance efficiently, while delaying preparations may create unnecessary operational and compliance challenges. The good news is that, with the right planning and back-office support, accounting firms can meet their new regulatory obligations without disrupting EOFY priorities.

At NCSGX, we help Australian accounting firms navigate the Tranche 2 AML/CTF reforms with practical, tailored support. If you'd like to assess your firm's readiness and identify the key compliance priorities, our team is here to help you build a clear and confident path to compliance.

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