Guide

Real estate and Tranche 2: what AUSTRAC expects

Four months into Tranche 2, AUSTRAC is issuing infringement notices. What it expects of real estate agencies in 2026-27, and the dates ahead.

By Matt Collis·Updated 27 October 2026·Reviewed 27 October 2026·7 min read

Since 1 July 2026, any agency that brokers the sale, purchase or transfer of real estate has been a reporting entity under the AML/CTF Act, with AUSTRAC as its regulator. Four months in, Australian Transaction Reports and Analysis Centre (AUSTRAC) has moved from education to enforcement. On 30 September 2026 it began issuing infringement notices to real estate, accounting and jewellery businesses it believes failed to enrol on time.

This page is the year-one view for principals and licensees in charge: what AUSTRAC says it expects of an agency in 2026-27, what has changed in its guidance since commencement, and the dates still ahead. The rules themselves, section by section, are in our guide to AML/CTF obligations for real estate agents.

What AUSTRAC expects of agencies in 2026-27

In its May 2026 regulator statement of expectations, AUSTRAC set out four things it expects of every newly regulated business in the 2026-27 financial year.

Key point

AUSTRAC expects newly regulated businesses to be enrolled, to have an anti-money laundering and counter-terrorism financing (AML/CTF) program and an AML/CTF compliance officer, to have trained their staff on the program, and to be ready to have a go at reporting when a suspicious matter arises.

ExpectationWhat it means for an agencyWhere to start
EnrolledApply to enrol no later than 28 days after you first provide a designated service. For an agency selling on 1 July 2026, that was 29 July 2026. Update your details within 14 days of any change.AUSTRAC: Enrol with us
A program and a compliance officerThe program is in place before you broker a sale. The compliance officer is at management level, resident in Australia and fit and proper. In an agency, AUSTRAC says this will typically be the licensee in charge.Starter kit: getting started and our page on compliance officer requirements
Staff trained on the programTraining covers your own program and risks. AUSTRAC’s smart agent’s guide is a free train-the-trainer package, but AUSTRAC says it does not by itself meet your obligation to give training specific to your business.Smart real estate agent’s guide
Ready to reportA suspicious matter report is due within 24 hours if the suspicion relates to terrorism financing, and within 3 business days in every other case. You must not tip the customer off.AUSTRAC: Suspicious matter reports

The same statement says AUSTRAC expects reporting entities to improve the quality of their controls and reports over time.

Key point

AUSTRAC’s position for 2026-27: “we expect effort, not perfection, during FY26/27.” It also said it would take early enforcement action against businesses that fail to enrol.

Enforcement so far

The 30 September notices were the early enforcement AUSTRAC had flagged. According to AUSTRAC’s media release:

  • the notices went to businesses AUSTRAC believes did not enrol within 28 days of providing a designated service
  • they were issued at $21,840 for a corporate entity and $4,368 for an individual, and can accrue daily
  • they followed formal requests for information that AUSTRAC sent in August to businesses that appeared to be providing designated services but had not enrolled
  • of the first group AUSTRAC looked at, around 90% have since enrolled or tried to, and AUSTRAC says it is actively looking for the rest.

As of 20 October 2026, 62,710 businesses were enrolled with AUSTRAC, a figure that covers every regulated sector, not only real estate. For the wider penalty regime, see AML non-compliance penalties.

What has changed in AUSTRAC’s guidance

AUSTRAC versions its guidance, and several real estate changes landed around commencement. If your program was built on an earlier version, these are the ones to check.

  • Starter kit release 1.1 (10 June 2026). The change register moves the counterparty deadline from 15 days to the earlier of 28 days after exchange or 3 days before settlement, adds a step to record what you did when a counterparty will not cooperate, streamlines beneficial ownership checks and moves the annual compliance report to the financial year. If you customised the kit, AUSTRAC says you must review the updates, decide whether to bring them into your program, and retire superseded versions.
  • Licences and leaseholds (31 August 2026). The real estate designated services page now explains that a standalone licence to occupy, as used in some retirement villages, is generally not real estate, while a leasehold of more than 30 years is.
  • Cash reporting (14 October 2026). The threshold transaction report page clarifies that only notes and coins your agency physically receives or pays count. A deposit into your bank account, or a buyer’s bank statement showing cash deposits, is the bank’s report, not yours.

One AUSTRAC page has not caught up. The starter kit’s customer examples (last updated 2 April 2026) still describe checking a buyer “within 15 days after exchange of contracts”. The Rules (section 6-32) and the 10 June release both say 28 days.

The dates still ahead

WhenWhatSource
1 July 2026 to 30 June 2027Your first annual compliance reporting periodAnnual compliance reports
Late 2026AUSTRAC guidance on whether existing fit and proper person checks can be recognised for compliance officersAML/CTF compliance officer
1 July to 30 September 2027Lodge your first compliance report in AUSTRAC OnlineAnnual compliance reports
30 June 2029 to 31 December 2030Your first independent evaluation, with the deadline set by the last two digits of your AUSTRAC account numberTransitional rules 2026

Only an administrator on your AUSTRAC Online account can lodge the compliance report, and AUSTRAC sends its reminders to the contacts on file, so it is worth checking now that your compliance officer’s email is current.

What StackGo does, and where the rest happens

StackGo runs the customer checks on each sale, for the seller and the buyer:

  • Intake: one link to a form that takes in the customer’s details, documents and consent.
  • Verify: biometric identity verification for individuals, and business verification with beneficial ownership for companies and trusts.
  • Screen: politically exposed person (PEP), sanctions and adverse media screening on every party.
  • Assess: a High, Medium or Low risk rating, with the decision, assessor and date recorded.
  • Monitor: monthly re-screening and risk-based reviews for repeat vendors and investors.

Enrolment, compliance reports and suspicious matter reports are lodged by your agency in AUSTRAC Online. Your program comes from your own risk assessment, or from AUSTRAC’s free starter kit if your agency fits its criteria, and AUSTRAC’s smart agent’s guide supports staff training.

To see the checks run on a test seller and buyer, book a demo.

Frequently asked questions

We missed the 28-day enrolment window. What now?

Enrol. AUSTRAC’s message in its 30 September release is that businesses with obligations should come forward, contact AUSTRAC and enrol. Infringement notices can accrue daily, so each day of delay adds to the exposure.

Our agency only manages rentals. Do we need to enrol?

No. Leases of 30 years or less are outside the definition of real estate, so property management is not a designated service. If you enrolled by mistake, request removal from the Reporting Entities Roll. While you stay on it, you still have obligations such as the annual compliance report.

Do we have to adopt every starter kit update?

AUSTRAC says that if you customised the kit, you must review each update and decide whether it belongs in your program, then replace or retire superseded documents so staff are not working from old rules.

When is our first compliance report due?

Between 1 July and 30 September 2027. It covers 1 July 2026 to 30 June 2027. The reporting period moved to the financial year, so older material that mentions a calendar year or a March due date is out of date.

Does AUSTRAC’s smart agent’s guide count as our staff training?

Not on its own. AUSTRAC says the package can be used as part of your training but does not fulfil the obligation to train staff on your own business and its risks.

What if AUSTRAC’s guidance doesn’t cover our situation?

AUSTRAC expects you to develop your own position, document why it is reasonable and keep records of any advice behind it. Where its reading of the law differs from yours, AUSTRAC says it will start with conversation, not enforcement.

Sources

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