The latest update on your Tranche 2 timeline: Where we are now and what to expect before July 2026
At the end of August 2025, AUSTRAC released the long-awaited Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Rules for Tranche 2 entities. These new Rules formally bring lawyers, accountants, real estate agents, conveyancers, and trust and company service providers (TCSPs) into the scope of Australia’s AML/CTF regime.
Right now, the Rules are being carefully reviewed and interpreted across the sector. Professional associations, peak bodies, regulators and solution providers like easyAML are all analysing what this means in practice for their members and clients.
One thing is certain: AUSTRAC is sticking to its published timeline. That means every Tranche 2 business has just 10 months to prepare for the reforms (which for many industries are the biggest reforms we’ve seen in years). And while that may sound daunting, the best thing to do is to use this time wisely to ensure you’re not left scrambling when obligations begin.
October 2025: AUSTRAC Tranche 2 core guidance and education program
October marks the next major milestone since the Rules were released. AUSTRAC has committed to publishing core Tranche 2 guidance. That is, high-level documents that outline how the Rules should be applied across all affected sectors.
Alongside the guidance, AUSTRAC will also roll out its Tranche 2 education program. We’ve seen some preliminary (more general) webinars from AUSTRAC already, but we expect phase two will include more detailed webinars, fact sheets and resources to help new reporting entities start building their understanding of AML/CTF compliance.
For your business, October is the time to:
- Review AUSTRAC’s published guidance as soon as it is available.
- Identify key staff who should attend AUSTRAC webinars or training.
- Begin mapping your services against the “designated services” list to confirm which activities bring you into scope.
October to November 2025: Consultation on Tranche 2 sector-specific guidance
After the release of the core guidance, AUSTRAC will turn to sector-specific consultation. Between October and November, targeted consultation will be conducted with professional associations and peak bodies, covering the unique risks and requirements of each Tranche 2 sector.
This stage is critical, because it shapes how the Rules will apply in detail to:
- Lawyers and legal practitioners involved in managing client funds, establishing structures or facilitating transactions.
- Accountants and auditors assisting clients with trust or company services, or handling financial transactions.
- Real estate agents and conveyancers representing clients in buying and selling property.
- Trust and company service providers (TCSPs) offering registered offices, directorships, or trustee services.
If your association is involved, engage with their updates. Your feedback is invaluable and will help shape their position to report back to AUSTRAC. If not, make sure you’re tracking sector-specific announcements so you don’t miss information. You can register for updates from AUSTRAC on their website and sign up for easyAML’s Readiness List.
December 2025: Tranche 2 AML/CTF starter program kits released
By December, AUSTRAC plans to publish starter program kits and sector-specific guidance for Tranche 2 entities. These documents are designed to give new reporting entities a head start in preparing their AML/CTF programs.
An AML/CTF program is the heart of your compliance obligations. It sets out:
- Part A: how your business identifies and manages AML/CTF risks (governance, risk assessment, training, independent review).
- Part B: how you verify customer identities and beneficial owners (customer due diligence).
For many Tranche 2 entities, December will be the first time they see a practical framework for what their program needs to contain.
Your priorities in December and early into 2026 should be to:
- Review the starter kit for your sector.
- Begin drafting or adapting your AML/CTF program.
- Identify systems, technology, or outsourcing you may need to implement.
- Allocate budget and resources for compliance in 2026.
March 2026: Tranche 2 AUSTRAC enrolment opens
The first 2026 milestone is 31 March 2026, when AUSTRAC opens enrolment for Tranche 2 entities. Every business providing designated services must be enrolled with AUSTRAC before they begin providing those services after 1 July 2026.
Enrolment is a formal step that places your business on AUSTRAC’s register of reporting entities. You’ll be asked to provide details about your business structure, services, and compliance contacts.
If you’ve used the October to December window wisely, you should be ready to enrol promptly in March, avoiding a last-minute rush.
July 2026: Tranche 2 AML/CTF obligations commence
From 1 July 2026, your business becomes fully subject to Australia’s AML/CTF regime. That means:
- Conducting customer due diligence before providing services.
- Reporting suspicious matters within 3 business days (24 hours if terrorism financing is suspected).
- Reporting threshold cash transactions ($10,000+) and international funds transfers within 10 business days.
- Submitting an annual compliance report to AUSTRAC.
- Maintaining and reviewing your AML/CTF program.
This is the date everything becomes enforceable. But with 10 months still on the clock, you can make sure your business is ready well before then.
How your business can use the next 10 months
Here are three practical steps to take now:
Stay informed
Subscribe to AUSTRAC updates, follow your professional association’s guidance, and join our Tranche 2 Readiness List to receive practical updates tailored for small and medium businesses.
Get your team involved
Identify who in your business will be responsible for AML/CTF compliance. Make sure they attend the AUSTRAC webinars and start building internal knowledge.
Plan your compliance pathway
Use the October to December 2025 milestones to map out your AML/CTF program. Decide whether you’ll build compliance processes internally, adopt technology solutions, or outsource components such as customer verification.
The countdown to Tranche 2 compliance is on
The release of the Tranche 2 Rules in August 2025 marks the start of the 10-month countdown to compliance. With AUSTRAC’s timeline clear and firm, there’s no time to waste. October will bring the first round of guidance and education, followed by consultation and starter kits before the year is out. By March 2026, enrollment will open, and from July 2026, your compliance obligations begin.
We know it’s a lot to take in, but you don’t have to face it alone. Join our Readiness List today and register for one of our upcoming webinars to ensure you get the latest updates and practical support to prepare your business.