Does property management need to comply with AUSTRAC?
Whether residential property managers and leasing agents are captured by AUSTRAC Tranche 2, and what the exclusion actually covers.
Residential property management is excluded from AUSTRAC Tranche 2. A property manager who does nothing but lease residential properties, collect rent, and manage tenancies is not a reporting entity and has no AML/CTF obligations.
Why it is excluded. The designated service under Item 53 of the AML/CTF Rules 2025 is buying or selling real property on behalf of another person, or otherwise facilitating the buying or selling of real property. Leasing is not buying or selling. A tenant acquires a right of occupation — not an interest in the property itself. No transfer of real property occurs, so the designated service definition is not triggered.
What the exclusion covers.
- Residential property management (rent collection, maintenance, tenancy management)
- Residential leasing (showing properties, executing lease agreements, bond lodgement)
- Short-term rental management
- Commercial leasing where no property transfer occurs
- Strata management
What is not excluded. The exclusion is narrower than most agencies assume. Commercial property sales are in scope. Buyer's agent representation is in scope. Auction marketing where you represent a seller is in scope. Any transaction that results in a transfer of real property triggers the obligations — regardless of whether the same business also does property management.
Mixed agencies — the critical point. Most Australian agencies operate across both property management and sales. The AML/CTF obligations apply to the entity that provides the designated service. If your agency has both a property management arm and a sales arm, the compliance obligations apply in full — even if 80% of your revenue is rental management. The exclusion provides a complete exemption only for businesses providing solely property management or leasing, never sales.
Operating as a sales agency and a managing agency through the same trading entity means you are in the regime. There is no partial enrolment.
What to do next: Map every revenue line in your business against Item 53. If any line involves representing a buyer or seller in a property transfer, your entity is in scope and the full obligations apply from 1 July 2026.