How to enrol with AUSTRAC as a real estate agent under Tranche 2

If your business sells or buys real estate on or after 1 July 2026, you must enrol with AUSTRAC by 29 July 2026, which is within 28 days of commencement. Enrolment opened on 31 March 2026, and it includes registering the designated services your business provides. If you start providing a designated service later than 1 July, you have 28 days from the first time you do so. That is the headline. The rest of this guide walks through what enrolment involves and the first compliance steps to stand up once you are on the register.

This guide reflects AUSTRAC guidance as at July 2026. It is general information, not legal or compliance advice. Rely on AUSTRAC and your own professional or legal adviser for decisions about your business.

What changed on 1 July 2026

From 1 July 2026, Australian real estate agents became reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act, through the AML/CTF Amendment Act 2024, widely known as Tranche 2. The regulator is AUSTRAC. This is the first time real estate agents have been captured. The same reform brings in lawyers, conveyancers, accountants, and dealers in precious metals and stones.

The obligations are now in effect. If you are reading this after 1 July, the clock is already running on your enrolment deadline. For the wider picture of what Tranche 2 means for the industry, see our overview of what AML/CTF Tranche 2 means for Australian real estate agents.

Step one: confirm your services are captured

Before you enrol, be clear on whether you provide a designated service. The captured service is any service provided in connection with the sale, purchase or transfer of real estate, regardless of the price, and whether you act for the vendor or the purchaser.

Real estate here means an interest in land in Australia. That covers a fee simple interest, which is ordinary ownership, a leasehold interest of more than 30 years, excluding options to renew or extend, or a land use entitlement.

Some services are not captured. Residential property management is out. So is leasing or renting under leases of 30 years or less. Valuers and mortgage brokers are not listed as providers of the real estate designated services commencing 1 July 2026. Put simply, selling and buying are in, and property management and ordinary leasing are out.

One point that catches agents by surprise: where you broker a sale, both the purchaser and the vendor are customers of the same reporting entity. You carry obligations to both parties, not only the one who engaged you.

Step two: enrol with AUSTRAC

Enrolment opened on 31 March 2026. If your business is providing a designated service on or after 1 July 2026, you must enrol with AUSTRAC by 29 July 2026. If you begin providing a designated service after that, you enrol within 28 days of first doing so.

Enrolment is not just a name on a list. It includes registering the designated services your business provides. Set aside time to work out which services apply to your business before you sit down to enrol, so the registration reflects what you actually do.

The official source of truth for the enrolment process is AUSTRAC at austrac.gov.au. Use their guidance for the mechanics, and check the deadline against your own commencement date.

Step three: put an AML/CTF program in place

Enrolling gets you on the register. It does not make you compliant on its own. The next thing to stand up is your AML/CTF program. In plain terms, that is a risk assessment plus written policies, procedures and controls.

The risk assessment is where you think through how your business could be used to move or hide money, given the clients you deal with, the transactions you handle, and how you deliver your services. The policies then set out what you will actually do about it. This is a document you maintain, not a one-off form, so build it in a way you can update as your business changes.

Step four: set up your customer due diligence process

Customer due diligence, or CDD, is the practical heart of the regime. It means you know and verify who your customer is before you provide a designated service. That includes initial CDD, giving each customer a risk rating, applying enhanced CDD for higher-risk customers, and carrying out ongoing CDD through the relationship.

Alongside identity, you screen customers for politically exposed persons, known as PEPs, and against targeted financial sanctions. Where it is relevant to risk, you also consider source of funds and source of wealth. Because both the vendor and the purchaser are your customers in a brokered sale, your process needs to cover both.

There is some timing flexibility. Initial CDD must generally be completed before you provide the designated service. AUSTRAC allows delaying it in limited cases where completing it first would disrupt the ordinary course of business, for example the short window between the fall of the hammer at auction and signing the contract of sale. Conditions apply, so treat this as an exception, not the rule. For a fuller walkthrough, see our guide to customer due diligence for real estate agents.

Step five: know your reporting and record-keeping duties

Two reporting duties sit on top of your program. You submit suspicious matter reports, or SMRs, to AUSTRAC where you form a relevant suspicion. You submit threshold transaction reports, or TTRs, for cash transactions of AUD 10,000 or more. Make sure whoever handles your transactions understands when each is triggered.

You also keep records for seven years. That covers the identity checks, the risk decisions, and the reporting you carry out. Build record-keeping into your process from day one rather than trying to reconstruct it later.

A short compliance checklist

• Confirm whether your services are captured. Sales, yes. Pure property management, no.
• Enrol with AUSTRAC. The deadline is 29 July 2026 for businesses operating from 1 July 2026.
• Register the designated services you provide as part of enrolment.
• Put an AML/CTF program in place: a risk assessment plus written policies.
• Set up a CDD process to verify vendors and purchasers, including PEP and sanctions screening.
• Understand your SMR and TTR reporting triggers.
• Keep records for seven years.

Why acting early matters

The AML/CTF Act carries significant civil penalties. For a body corporate, exposure runs up to 100,000 penalty units, in the order of 33 million dollars. For a person other than a body corporate, up to 20,000 penalty units, in the order of 6.6 million dollars. Per-contravention exposure applies, and AUSTRAC has a track record of large enforcement outcomes in other sectors. That penalty scale sits under the AML/CTF Act and is enforced by AUSTRAC. None of this is a reason to panic, but it is a reason to start now rather than late.

The practical squeeze on your week

Tranche 2 does not just add rules. It adds real admin and time pressure on top of an already full week: identity checks on both sides of every deal, screening, records, and a program to maintain. That makes the hours you protect elsewhere matter more. NeuraCall runs your prospecting follow-up and chasing for you, in your own name, so the time you free up can go to the compliance work and the client conversations only you can do. If that sounds useful, you can book a call to see how it fits your week.

For the authoritative detail, always go to AUSTRAC at austrac.gov.au and speak to your own adviser. This guide is general information about the AML/CTF Amendment Act 2024 and is not legal or compliance advice.