Does property management need to comply with AUSTRAC?
Whether property managers and leasing agents are captured by Tranche 2, what the exclusion actually covers, and where mixed agencies sit.
In short
Pure residential property management is outside the AML/CTF regime — leasing isn't a transfer of real estate within the Act's definition. But the moment the same legal entity does any sales work, the whole entity is in scope through that arm. There is no partial enrolment.
Residential property management is outside Tranche 2. A business that 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 real estate designated service at s 6, Table 5, Item 1 of the AML/CTF Act 2006 (Cth) is "brokering the sale, purchase or transfer of real estate." Section 5 of the Act defines "real estate" so that it excludes leasehold interests of 30 years or less. A tenant signing a residential or ordinary commercial lease acquires a right of occupation, not a transfer of real estate within that definition. The designated service is not triggered.
What the exclusion covers
- Residential property management — rent collection, maintenance, tenancy management
- Residential leasing — open homes, application processing, lease signing, bond lodgement
- Short-term rental management
- Ordinary commercial leasing where the term is 30 years or less
- Strata management
- Standalone property valuations
What is not excluded. The exclusion is narrower than most principals assume. Any transaction that brokers a transfer of real estate is in scope, regardless of whether the same business also runs a rent roll:
- Property sales (residential or commercial)
- Buyer's agent representation
- Auction marketing where you represent the seller
- Off-the-plan and project marketing
- Long-term commercial leases — anything exceeding 30 years sits inside the s 5 definition and is in scope
Mixed agencies — the critical point
Most Australian agencies operate across both property management and sales. The obligations apply to the legal entity that provides the designated service. If your company has both arms and one of them brokers a sale, the company is a reporting entity in full. Even if 80 percent of your revenue is rent management, the whole entity is in. There is no partial enrolment and no revenue-weighted programme.
Operating a sales business and a managing-agency business through the same trading entity means the entity is in the regime. The only way property management sits entirely outside Tranche 2 is for it to be in a separate legal entity that never brokers a sale.
What to do next. Map every revenue line in your business against Table 5 Item 1. If any line involves brokering a transfer of real estate, your entity is in scope and the full obligations apply from 1 July 2026. If you run sales and rentals through separate companies, confirm with your accountant that the corporate separation is clean — shared bank accounts and intermingled records erode it quickly.
Frequently asked questions
- Is rent-roll work captured by Tranche 2?
- No. Collecting rent, managing tenancies and routine inspections are not designated services. A pure property-management business has no AUSTRAC obligations.
- What if my agency does both rentals and sales?
- The legal entity is in. There is no partial enrolment, no carve-out for the rental arm, and no proportionality based on revenue split. One designated service pulls in the whole reporting entity.
- Is commercial leasing a designated service?
- Usually not. Section 5 of the Act excludes leasehold interests of 30 years or less from the definition of real estate. Only an unusually long commercial lease — over 30 years — sits inside the designated service.