When does Tranche 2 commence for real estate?

It commenced on 1 July 2026. A business must apply to enrol within 28 days after it starts providing a designated service (s 51B). For agencies already operating on 1 July 2026, that deadline was 29 July 2026. A business that starts brokering later has 28 days from its own start date.

Who does Tranche 2 capture?

AUSTRAC's 1 July 2026 announcement names real estate agents, lawyers, conveyancers, accountants, and dealers in precious metals and stones. In real estate, the designated services cover seller's and buyer's agents (s 6, table 5, item 1). They also cover businesses such as developers that sell real estate without an independent agent (item 2). The obligations attach to the person that provides the designated service (s 5).

Why has real estate been brought in?

AUSTRAC says criminals target real estate and professional services to move and hide illicit money, often using trust and company structures, and that bringing these sectors in closes those gaps. AUSTRAC has also noted that Australia faces a mutual evaluation by the Financial Action Task Force commencing in 2026.

What is AUSTRAC Tranche 2 and why does it apply to me?

Why real estate agencies were brought into Australia's AML/CTF regime, what has applied since 1 July 2026, and the deadlines that came with it.

In short

Tranche 2 is the shorthand for the 2024 reforms that extended Australia's anti-money laundering laws to real estate agents, lawyers, conveyancers, accountants, and dealers in precious metals and stones. For real estate, the obligations began on 1 July 2026. Any business that brokers the sale, purchase or transfer of real estate is a reporting entity. It must enrol with AUSTRAC, run an AML/CTF programme and carry out customer due diligence. It must also report suspicious matters and large cash transactions, and keep records for seven years.

The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) has been in force since 2006. The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Act No. 110 of 2024) extended it to new sectors. The new real estate and professional services obligations began on 1 July 2026. "Tranche 2" is the common shorthand for that extension.

Why real estate. AUSTRAC's 1 July 2026 announcement says criminals target real estate and professional services to move and hide illicit money, often using trust and company structures. It describes bringing these sectors in as closing those gaps. AUSTRAC has also said the timing reflects Australia's mutual evaluation by the Financial Action Task Force, commencing in 2026.

Who is in. For real estate there are two designated services:

brokering the sale, purchase or transfer of real estate for a buyer, seller, transferee or transferor in the course of carrying on a business (s 6, table 5, item 1), which covers seller's agents and buyer's agents;
selling or transferring real estate in the course of a business of selling real estate, where no independent agent brokers the sale (item 2), for example a developer selling off the plan through in-house staff.

A person that provides a designated service is a reporting entity (s 5).

The rules behind it. The detail sits in the AML/CTF Rules 2025 (F2025L01026), registered on 29 August 2025 and in force from 31 March 2026. The original 2007 rules instrument, the AML/CTF Rules Instrument 2007 (No. 1), was not simply replaced. It remains in force as the AML/CTF (Class Exemptions and Other Matters) Rules 2007 and still holds some exemptions, including the carve-out for rental money held in a trust account. The old "Part A / Part B" programme structure does not appear in the current Act or Rules.

What applies. A reporting entity must:

enrol with AUSTRAC within 28 days after it starts providing a designated service (s 51B);
have an AML/CTF programme, made up of a risk assessment and policies (s 26B), documented before it first provides a designated service (s 26F(8); Rule 5-15(1));
designate an AML/CTF compliance officer within 28 days and notify AUSTRAC within 14 days after that (ss 26K, 26M);
carry out customer due diligence on its customers, both the seller and the buyer, before providing the service, subject to the real estate timing relief (ss 28–29);
monitor customers for unusual transactions and behaviours (s 30);
report suspicious matters (s 41) and cash transactions of $10,000 or more (s 43);
train staff and check their suitability (s 26F(4)(d)–(e));
arrange an independent evaluation of the programme at least once every 3 years (s 26F(4)(f));
keep records for 7 years (Part 10 and s 116).

What AUSTRAC said about day one. AUSTRAC's 1 July 2026 release said businesses "must already have an AML/CTF program and AML compliance officer in place, be training staff and ready to report", with until 29 July to enrol. In July 2025 AUSTRAC said it does "not expect perfection on day one". After 1 July 2026, it said, its enforcement in the new sectors would focus on entities that wilfully ignore the obligation to enrol, or that it suspects are complicit with, or wilfully blind to, money laundering. On 1 July 2026 the CEO put it more directly: "the expectation is compliance, and the alternative is enforcement."

Personal exposure. The obligations sit with the reporting entity. Directors and staff are not liable just because of their role. A person who is knowingly concerned in, or aids, a contravention of a civil penalty provision can be personally liable (s 174). Some offences, such as tipping off, apply to officers and employees directly (s 123).

What to do next. If your agency brokers sales and has not yet enrolled, do it now. The 28-day window for agencies operating on 1 July 2026 closed on 29 July 2026, and each day late is a further contravention. Then check that your programme was documented, your compliance officer was notified to AUSTRAC, and your CDD process covers both sides of every sale.

Up next · Does It Apply To You?

What is a "designated service" — and which of mine count?

Which parts of your real estate business are inside the AML/CTF regime, and which sit outside it.

Frequently asked questions

When does Tranche 2 commence for real estate?: It commenced on 1 July 2026. A business must apply to enrol within 28 days after it starts providing a designated service (s 51B). For agencies already operating on 1 July 2026, that deadline was 29 July 2026. A business that starts brokering later has 28 days from its own start date.
Who does Tranche 2 capture?: AUSTRAC's 1 July 2026 announcement names real estate agents, lawyers, conveyancers, accountants, and dealers in precious metals and stones. In real estate, the designated services cover seller's and buyer's agents (s 6, table 5, item 1). They also cover businesses such as developers that sell real estate without an independent agent (item 2). The obligations attach to the person that provides the designated service (s 5).
Why has real estate been brought in?: AUSTRAC says criminals target real estate and professional services to move and hide illicit money, often using trust and company structures, and that bringing these sectors in closes those gaps. AUSTRAC has also noted that Australia faces a mutual evaluation by the Financial Action Task Force commencing in 2026.

Back to The Basics