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Here’s what you missed in Tranche 2 compliance updates (and what to do if you haven’t started yet)

Published November 20, 2025

We’re almost through November. Decorations are popping up, inboxes are overflowing, and that final sprint to the end of the year is well and truly on. It’s easy to tell yourself, “I’ll deal with Tranche 2 next year.” After all, July 2026 still sounds like ages away. But as always happens at this time of year, soon enough you’ll blink, the silly season will be over, and 2026 will be staring you in the face.

While seven months might feel like a long time, AUSTRAC enrolment opens in March, and if you leave it too long to start laying your compliance foundations, you’ll be facing the same end-of-financial-year chaos, plus a whole new set of AML/CTF obligations on top.

So, if you’ve been hearing about Tranche 2 but haven’t quite got around to doing anything yet, this article’s for you. Let’s get you caught up, and show you how to get back on the front foot before it’s crunch time.

A quick recap: what Tranche 2 is all about

Tranche 2 is the long-awaited extension of Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws. From 1 July 2026, AML/CTF obligations will apply to a much wider group of businesses, including:

These businesses will soon join the roughly 17,000 existing “Tranche 1” reporting entities already supervised by AUSTRAC. Once Tranche 2 takes effect, that number is expected to jump to 100,000 or more. That means a lot of small and medium businesses will suddenly be entering the compliance space, many for the very first time.

What’s happened so far: the key updates you might have missed

If you’ve been too busy serving clients, wrapping up projects, or just keeping your head above water (we get it), here’s a quick catch-up on what’s already happened:

Late August 2025: The AML/CTF Rules were released by AUSTRAC

These Rules set out the framework for how Tranche 2 businesses will need to enrol, identify customers, assess risk, and report suspicious or threshold transactions.

October 2025: AUSTRAC released its core Reforms Guidance

This guidance was made up of some 80,000-words, diving deep into what an effective AML/CTF program looks like. It looked at things like expectations around governance, customer due diligence (CDD), transaction monitoring, staff training, and independent reviews.

From late January 2026: Sector-specific guidance and “starter kits” are expected

These will include tailored resources for each profession — for example, real estate, law, conveyancing, and accounting — so you can see how to adapt the general Rules to your industry.

31 March 2026: Enrolment opens for Tranche 2 entities 

You’ll need to enrol with AUSTRAC no later than 28 days after you start delivering Designated Services. For existing businesses, this means you have from 31 March 2026 to 29 July 2026 at the latest to enrol.

We already know what’s coming. The fine-tuning will arrive early next year as the sector-specific guidance is issued, but businesses don't need to wait until then to get a handle on what's happening. 

Why you can’t afford to wait

You might be thinking, “It’s fine, we’ll start once everything’s finalised.” But that thinking will cost you. Here’s why:

March is closer than it feels.

AUSTRAC’s enrolment window opens just three months into the new year. By then, you should already know who your compliance officer is, how you’ll handle customer verification, and what systems you’ll use to collect and store records.

Your team will need time to learn.

AML/CTF isn’t something you can “wing.” Staff will need training, you’ll need policies and procedures in writing, and your systems need to be ready to generate evidence and audit trails.

Avoid the June panic.

If you wait until late in the financial year, you’ll be juggling EOFY work, client deadlines, and compliance set-up all at once. That’s when things get rushed (and mistakes happen).

AUSTRAC penalties are real.

AUSTRAC has a long record of enforcing compliance (and naming names). Fines for failing to enrol or meet reporting obligations can be substantial, even for small businesses.

Clients will expect you to be ready.

Tranche 2 isn’t just about regulators. Your referral partners, lenders, and even clients will soon expect you to have AML processes in place. Falling behind could cost you credibility and opportunities.

So, what should you be doing now?

Considering how close we are to Christmas and the end of the year, here is a realistic action plan to get you moving, so that you can enjoy the summer break knowing you’re not starting from scratch in 2026.

1. Nominate (or identify) your Compliance Officer

Every business will need one. This person oversees your AML/CTF program, manages customer due diligence, ensures reporting obligations are met, and liaises with AUSTRAC if needed.

If you’re a small business, that’s often the owner or director. If you’re larger, it could be a practice manager or senior staff member. The key is that they have authority, resources and time to manage compliance.

2. Start building your understanding

Spend an hour a week between now and Christmas getting across the basics. This might look like:

AUSTRAC doesn’t expect that you’ll become an expert overnight. What they do expect though is that you’ll make the effort to understand what’s coming, what it means for you and consider how you’ll apply the requirements to your business.

3. Look at your current processes

You probably already do some parts of AML without realising it. Things like like verifying ID for clients, keeping transaction records, or flagging anything suspicious. Now’s the time to ask:

Consider what changes may be required to your current documentation - such as Authorities to Act, Fee Agreements, employee position descriptions and more.

Even jotting down what you think your current process is will make writing your AML/CTF program far easier next year.

4. Strengthen your record-keeping and data security

AUSTRAC requires you to keep AML/CTF records for at least seven years, and they must be stored securely and be retrievable if requested. Now is the time to check some of the following both with yourself/your team and with your IT provider:

If you identify weak spots, fix them early. Don’t wait until mid-2026 when you’re already under pressure.

5. Start staff awareness training

Before you can comply, your team needs to understand the new regulations, and why compliance matters. Run a short session with your team before Christmas to introduce:

Even a basic level of awareness will make a huge difference once formal obligations kick in.

6. Stay connected through industry updates

Between now and March, AUSTRAC and industry bodies will continue releasing new guidance and templates. AUSTRAC’s website, your industry body (AIC, REIA, CPA, CA ANZ, Law Council, etc.) and us here at easyAML will continue to share news and updates, and break down new information into simple, actionable steps for SMEs.

What if you haven’t started at all?

You’re not behind. Yet. But the window for an easy, stress-free start is closing. If you make a start before the end of the year, you’ll give yourself time to make thoughtful decisions (not rushed ones), especially when it comes to your enrolment, as well as breathing space to train your staff and refine your processes.

If you wait until next year? You’ll be racing the clock, competing for limited support from consultants, and trying to interpret guidance while juggling day-to-day work.

The good news: you don’t have to do it alone

Tranche 2 might feel complex, but help is available. easyAML was built specifically for small and medium businesses just like yours entering the AML/CTF regime for the first time. Our platform gives you one single place to manage your AML/CTF program, risk assessments, customer due diligence, training, reporting and more.

Our next easyAML webinar will walk you through:

Register today to get clarity, confidence, and a plan to move forward calmly, so you can head into the new year knowing you’re ready for whatever 2026 brings.