Accountant AML compliance cost: four options compared
The government’s 2024 Impact Analysis estimated AML/CTF compliance would cost an average accounting business about A$13,700 upfront and A$17,000 a year. Most of it is customer due diligence and the AML/CTF program. You can use AUSTRAC’s starter kit, an adviser or software, but your firm stays responsible.
This guide is for partners and practice managers at accounting firms regulated by AUSTRAC from 1 July 2026. Cost figures come from the government’s Impact Analysis and AUSTRAC’s own guidance, checked on 21 October 2026.
What does AML compliance cost an accounting firm?
The best public estimate is the Impact Analysis the Attorney-General’s Department prepared for the 2024 reforms. Nous Group built it from surveys of businesses about their expected compliance costs.
For accounting services, it put the average cost per business at about A$13,700 upfront and A$17,000 a year after that. The estimate covers staff time, external advice and systems.
Size matters more than industry. The analysis also broke down its average for every newly regulated business by annual turnover:
| Annual turnover | Upfront | Each year |
|---|---|---|
| Up to A$200,000 | A$4,460 | A$6,020 |
| A$200,000 to A$2 million | A$28,650 | A$33,230 |
| A$2 million to A$10 million | A$38,130 | A$43,750 |
| Over A$10 million | A$85,550 | A$82,660 |
Treat these as a guide, not a quote. The surveys ran in 2024, before the final AML/CTF Rules and the Australian Transaction Reports and Analysis Centre (AUSTRAC) guidance were written. The analysis expected that work to lower costs further.
Where does the money go?
Most of the cost sits in two obligations. Customer due diligence and the AML/CTF program are the largest upfront and ongoing costs in the analysis.
For a business with turnover of A$200,000 to A$2 million, the program averaged A$11,240 upfront and A$17,550 a year. Customer due diligence averaged A$12,140 upfront and A$15,170 a year.
Reporting and record keeping cost more to set up than to run. Enrolment averaged A$230 for businesses under A$2 million.
From 1 July 2026, AUSTRAC says a regulated firm must already have:
- an AML/CTF program, built on an ML/TF risk assessment
- an AML/CTF compliance officer
- staff who are being trained
- a way to report to AUSTRAC
Each of those costs something whichever option you choose. The options below change who does the work, not whether it is done.
What are the four ways to comply?
Four ways an accounting firm can meet its AML/CTF obligations
| Option | What you do | Who does the work | What is left for you |
|---|---|---|---|
| AUSTRAC starter kit, in-house | Customise AUSTRAC’s accountant program starter kit into your own program | Your compliance officer, typically the office manager | Checks on every client. The kit is designed for practices with 15 or fewer personnel that meet all its criteria |
| Adviser builds the program | Pay a consultant or lawyer to write or tailor your program | The adviser, once, under a written agreement | Running the program, checks on every client, and a separate independent evaluator |
| Standalone AML software | Run identity checks and screening in a separate system | Your staff, in a second system | The program, training and oversight of the provider |
| Checks inside your practice software | Run identity checks and screening from the client record | Your staff, in the software they already use | The program, training and oversight of the provider |
Sources: AUSTRAC, Accounting program starter kit: Getting started; AUSTRAC, Using outsourcing to help meet your obligations Reviewed
Most firms use one of four approaches, or a mix. They differ in who does the work and what is left for you to do.
AUSTRAC lets you outsource AML/CTF functions, once or on an ongoing basis. Its outsourcing guidance names managing the cost of compliance as one reason to do it.
Key point
Under Australia’s AML/CTF Act, a reporting entity that outsources AML/CTF functions remains responsible for compliance and incurs any penalty for a breach.
So the cheapest option is the one your firm can run properly. A program that exists only on paper still leaves the firm exposed.
What does the starter kit route involve?
AUSTRAC publishes an accountant program starter kit. It holds a risk assessment, policies, processes and forms that you customise into your own program.
It is designed for practices with 15 or fewer personnel, counting admin staff. Your clients should mostly be Australian-resident individuals, and you should not regularly deal with high-risk clients.
If your practice does not meet every criterion, you cannot rely on the kit alone. Large practices will generally need stronger or additional controls, AUSTRAC says.
The main cost is staff time. AUSTRAC expects your compliance officer, typically the office manager, to customise the kit. You still need a way to verify identity and screen clients every time.
What do you pay for when you hire an adviser?
A consultant or lawyer can write or tailor your program. AUSTRAC treats this as one-time outsourcing and expects a written agreement with a performance standard.
Before you sign, you must do due diligence on the provider. AUSTRAC’s outsourcing checklist warns against generic templates offered to every business, and against providers with no support after purchase.
Plan for the evaluation too. The evaluator must not have helped develop your program, so the adviser who built it cannot also evaluate it.
What changes when you use software?
Software covers the day-to-day checks, not the program. When you outsource customer due diligence, monitoring or reporting on an ongoing basis, AUSTRAC expects more oversight than for a one-off build.
A standalone platform runs checks in a separate system. Software inside your practice tools runs them from the client record. Either way, AUSTRAC’s checklist says to confirm your staff can use it or integrate it with your systems.
Records matter whichever tool you use. AUSTRAC’s record keeping checklist says to keep customer due diligence records for at least 7 years after the relationship ends.
When do the costs fall?
When the AML/CTF costs fall for a newly regulated accounting firm
- Set up before obligations start: enrolment opened 31 March 2026, obligations started 1 July (enrol by 29 July)
- First year reported on: 1 July 2026 to 30 June 2027
- Lodge the first annual compliance report: 1 July to 30 September 2027
- First independent evaluation due: 30 June 2029 to 31 December 2030, set by your AUSTRAC account number
Sources: AUSTRAC, Anti-money laundering and counter terrorism laws cover thousands more businesses (1 July 2026); AUSTRAC, Annual compliance reports; AUSTRAC, AML/CTF transitional rules 2026 Reviewed
Upfront costs fell before 1 July 2026, when the obligations started. A firm already providing designated services that day had until 29 July 2026 to enrol.
Ongoing costs recur every year. Your first annual compliance report covers 1 July 2026 to 30 June 2027, and you lodge it between 1 July and 30 September 2027.
Key point
Under Australia’s AML/CTF Act, a reporting entity must have its AML/CTF program independently evaluated at least once every 3 years.
Your first evaluation is due between 30 June 2029 and 31 December 2030. The transitional rules set the date by the last two digits of your AUSTRAC account number.
The evaluator can be internal or external, as long as they are independent. That means not your compliance officer or anyone in the compliance team.
How do you choose an option?
Start with the starter kit criteria. If your practice meets all of them, the kit plus a reliable way to run checks may cover most of what you need.
If it does not, budget for adviser time to tailor the program and for independent evaluation later. Then choose the tool your staff will use on every client.
Weigh the cost of getting it wrong as well. Under Australia’s AML/CTF Act, the maximum civil penalty is A$36.4 million per contravention for a company, and A$7.28 million for an individual. See AML non-compliance penalties.
Frequently asked questions
Do small accounting firms pay the AUSTRAC levy?
Usually not. AUSTRAC says the industry contribution levy is usually paid by medium to large businesses, such as those with earnings of A$100 million or more or a high volume of transaction reports.
Can I use the starter kit with more than 15 staff?
You can adapt parts of it. But AUSTRAC says a practice that does not meet every criterion cannot rely on the kit to meet its expectations, and must assess what to change.
Can the consultant who wrote my program evaluate it?
No. AUSTRAC expects an independent evaluator not to have been involved in developing your program, systems and controls, or in assessing your money laundering and terrorism financing (ML/TF) risks.
Who pays if an outsourced provider gets it wrong?
Generally your firm does. AUSTRAC says you remain legally liable for any breach of your obligations under an outsourcing arrangement, and you incur any penalty that follows.
Next steps
Check which of your services are designated services for accountants, then start your risk assessment. Our AUSTRAC program starter kit guide walks through the kit.
StackGo’s IdentityCheck runs know your customer (KYC) and AML identity checks inside the customer relationship management (CRM) or practice management software your team already uses. Results are written back to the client record. See how IdentityCheck supports AUSTRAC Tranche 2 compliance, and our pricing.
Sources
The facts on this page come from these sources, checked on 21 October 2026.
- Attorney-General’s Department, Impact Analysis: AML/CTF regime reforms (August 2024; Tables 18, 19 and Figures 6, 7)
- AUSTRAC, Anti-money laundering and counter terrorism laws cover thousands more businesses (1 July 2026)
- AUSTRAC, Accounting program starter kit: Getting started
- AUSTRAC, Using outsourcing to help meet your obligations
- AUSTRAC, Step 5: Conduct an independent evaluation
- AUSTRAC, AML/CTF transitional rules 2026
- AUSTRAC, Industry contribution levy