AML/CTF Rules 2025: Enrolment for accounting

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Understanding AML/CTF Rules 2025 Part 3: Enrolment, and what it means for accounting practices

From 31 March 2026, Australian accounting practices that provide designated services under the AML/CTF Act must enrol with AUSTRAC as reporting entities. This applies to services such as audit, tax advisory, and managing trust accounts. Enrolment is mandatory, and practices cannot legally provide these services until registered.

The enrolment period for Tranche 2 entities runs from 31 March to 29 July 2026. Knowing what AUSTRAC requires and preparing early will help firms complete enrolment smoothly and stay compliant.

What enrolment means

From 31 March 2026, accounting firms that provide “designated services” under the AML/CTF Act must enrol with AUSTRAC as reporting entities. This includes audit, tax advisory and trust account services. Enrolment is not optional: you cannot legally provide these services until you’ve completed enrolment. 

Enrolment for tranche 2 entities opens on 31 March 2026 and you must be enrolled by 29 July 2026.

What AUSTRAC needs to know

When enrolling, firms must provide:

• Designated services: which services you provide or plan to provide, including start dates and whether they are delivered in Australia or overseas.
• Business structure and professional associations: company, partnership, trust, or association. Include professional memberships (e.g. CA ANZ, CPA Australia, IPA).
• Control: beneficial ownership, directors or partners and contact details
• Scale: staff numbers, annual turnover, and whether you qualify as a small business.
• Reporting groups: confirmation if you are part of a reporting group and whether you are the lead. If you’re not the lead, then state who is.

Extra details for certain types of organisations

Beyond the basics, AUSTRAC also asks for extra details based on your firm’s legal structure. The common thread is the same: they want clarity on who controls and makes decisions in the organisation.

• Partnerships: details of individual partners who make key decisions (names, addresses, DOBs, government IDs) or, if partners are companies, trusts or associations, their equivalent details.
• Companies: names and dates of birth of directors, director IDs, where you’re incorporated or registered and overseas business addresses. If you have a parent company, you’ll need its name, address, country of residence and identifier.
• Trusts: type of trust, former names, and details of all trustees (individual or corporate).
• Associations or co-operatives: details of the main decision-makers (names, addresses, DOBs, government IDs).

Why this matters for accounting firms

• Multiple legal vehicles: Many accounting practices run audit, advisory, and wealth management arms through separate companies or trusts. Each may need to be declared in enrolment, which can be more complex than firms expect.
• Ongoing changes: Partner retirements, new incorporations, or mergers all trigger a duty to update AUSTRAC.

Tips for enrolling smoothly

• Map your services: Identify which parts of your practice involve designated services (conveyancing, managing trust funds, complex corporate transactions).
• Collect the information: Gather partner or director details, including dates of birth and government IDs.
• Create an internal register: Set up a central register for governance and ownership details so you’re not scrambling across multiple spreadsheets every time AUSTRAC needs an update.
• Check structures: Define the firm’s structure before filling in the enrolment form.
• Nominate an enrolment officer: Decide who in the firm will complete and declare the enrolment.
• Plan for updates: Put systems in place to update AUSTRAC whenever partners change, services expand, or contact details shift.
• Check twice: Errors in information will slow you down.
• Use support: AUSTRAC’s helpdesk and FAQs are extensive
• Call in experts if needed: A compliance adviser can save time (and stress)
• Avoid peak times: Test the system off-peak to iron out glitches.
• Enrol early: ~90,000 companies need to register and AUSTRAC's systems will be under strain. Submitting your enrollment early gives you time to resolve any issues that may arise.

Immediate next steps

• Map your firm’s services and confirm which trigger enrolment.
• Gather corporate and governance information for AUSTRAC.
• Discuss with franchise or network leads whether to enrol centrally or individually.
• Prepare to update enrolment after structural changes.