AML/CTF Tranche 2: the Dates That Bind
Enrolment falls due 28 days after a firm's first designated service. The first Tranche 2 compliance report is due by 30 September 2027. Our site had that wrong.
AML/CTF Tranche 2 comes with three dates. Enrolment with AUSTRAC opened on 31 March 2026. Obligations began on 1 July 2026. The first annual compliance report falls due in 2027. AUSTRAC's six new sectors are trust and company service providers, dealers in precious metals and stones, real estate agents, law firms, conveyancers and accountants. Our own Tranche 2 pages have carried those three dates since May 2026. We had the third one wrong until 20 October 2026.
Read as a calendar, the three dates describe a comfortable year. Read as obligations, they are different kinds of thing. The first is a window that opened. The second is the day duties started to accrue. Only the third is a date by which something must be lodged, which also makes it the furthest away. The date behind AUSTRAC's first Tranche 2 infringement notices is none of the three.
Enrolment opened on 31 March and falls due 28 days after the first service
31 March 2026 is the day AUSTRAC began accepting enrolments. It is an opening date. The rule that binds is the one in AUSTRAC's media release of 30 September 2026: a business must enrol within 28 days of providing a designated service. A firm that provided one on 1 July 2026, the day the obligations began, had until 29 July 2026 to enrol. A firm whose first designated service came later has a later deadline.
In that release AUSTRAC said it had begun issuing infringement notices to businesses in the real estate, accounting and jewellery sectors that it believes failed to enrol in time. At the amounts in the release, a notice costs a corporate entity A$21,840 and an individual A$4,368. The amounts can accrue each day.
Our own readiness tool lost the rule. Until 23 October 2026 it told a firm that enrolment opened on 31 March 2026, that it was mandatory for every Tranche 2 entity and that providing designated services without enrolment was unlawful once obligations began on 1 July 2026. It said nothing about 28 days. Taken at its word, that put the deadline at a firm's first designated service, earlier than the 28-day rule AUSTRAC is issuing notices under. The rule itself was missing. We added it on 23 October 2026.
1 July is a start date with no lodgement of its own
On 1 July 2026 every designated service in the six sectors began to carry AML/CTF obligations. The date set no lodgement of its own. What it started was the count of designated services that the enrolment clock runs from.
Our compliance page said, until 23 October 2026, that the 2024 reforms extend the regime to additional sectors and that commencement is staged. The staging is real. It belongs to the 2024 reforms as a whole. For the six new sectors AUSTRAC gives one date, 1 July 2026, with no later start for any of them. We checked that against AUSTRAC's site on 20 October 2026 and reworded the page on 23 October 2026 to say that the six sectors' obligations began on 1 July 2026.
The report date we published was wrong
Until 20 October 2026 our six profession pages, our readiness tool and our own evidence notes said the first annual compliance report was due by 31 March 2027. The pages had carried that date since 25 May 2026. It is a calendar-year date. AUSTRAC's annual compliance reports page had given a financial-year period since 1 April 2026, before we published ours.
That AUSTRAC page gives the next reporting period as 1 July 2026 to 30 June 2027 and cites s 47(2) of the AML/CTF Act 2006 and s 9-9 of the Rules. A report is submitted within three months of the period ending, between 1 July and 30 September. A separate AUSTRAC page says Tranche 2 entities did not report for the 2025 calendar year. That page is its top tips for the 2025 compliance report, dated 16 December 2025.
Put the two pages together and the first Tranche 2 report covers 1 July 2026 to 30 June 2027. It is due by 30 September 2027. AUSTRAC does not call it the first Tranche 2 report in so many words. The date has to be assembled from a reporting period on one page and a statement on another. We never did the assembly. Our evidence note for regulatory dates, written on 16 September 2026, took its dates from our own compliance pages instead of from AUSTRAC. It inherited the wrong date and then stood behind it until someone checked the regulator's site on 20 October 2026. The wrong date was six months ahead of the right one, which is the cheaper direction to be wrong in.
Our pick for the hardest start is dealers in precious metals and stones
The evidence we hold singles out two of the six sectors. Dealers in precious metals and stones carry a Threshold Transaction Report obligation on cash dealings at or above A$10,000. Law firms carry legal professional privilege considerations that the other five sectors do not. That is one line on each. The evidence does not rank them, so what follows is our judgement.
We put dealers first for two reasons. The obligation the evidence names for them is tested on a cash dealing, so it has been live from the first dealing at or above A$10,000 after 1 July 2026. AUSTRAC's release also names the jewellery sector among the three receiving infringement notices, which we read as the precious metals and stones category. Real estate and accounting are on the same list with no distinguishing obligation in our evidence. Dealers are the one sector with both.
Privilege is a different kind of problem. The evidence we hold says nothing more about it than that law firms have it. Our ranking rests on what has a dollar figure and an infringement notice behind it, which privilege does not.
The only date still ahead is a lodgement date for a period that is running
Of the three dates, two are behind every firm whose first designated service is more than 28 days old. Its enrolment deadline has passed. Its obligations have accrued since that first service.
The one date still ahead is 30 September 2027. It is the last day to lodge a report on the period 1 July 2026 to 30 June 2027, so the period closes three months before the date on the calendar. We had that date wrong for five months. For most of those months the period it covers was running.