The July 2026 AML/CTF deadline: what real estate agents need to do now

You've decided to get your agency compliant before the AUSTRAC deadline. The hard part is knowing what to do and in what order. This post gives you a plain-English action plan with month-by-month milestones.

Two dates you must not confuse

Before the action plan, let's clear up the most common source of confusion.

1 July 2026 — obligations commence. From this date, you must comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 as a real estate agent. This means your AML/CTF program must be in place, you must have a compliance officer appointed, and you must start conducting customer due diligence (CDD) on every client before providing a designated service.

29 July 2026 — enrolment deadline. You have until this date to complete your enrolment with AUSTRAC via AUSTRAC Online, and to notify AUSTRAC of your AML/CTF Compliance Officer. Think of this as the administrative deadline — but your obligations are already running from 1 July.

Obligations start on 1 July. The paperwork confirming you're set up is due 29 July. Don't treat that later date as breathing room — your compliance work needs to be done before 1 July.

Will the deadline be extended? The 1 July 2026 date is set in legislation (the AML/CTF Amendment Act 2024). Changing it would require an act of Parliament, and with Australia's FATF evaluation also scheduled for 2026, an extension is highly unlikely. Plan for 1 July.

Your month-by-month action plan

March 2026 — Enrol and assess

Step 1: Enrol with AUSTRAC

Enrolment opens on 31 March 2026. This is your first formal step. Log in to AUSTRAC Online and complete your enrolment as a newly regulated entity.

Sole traders enrol as individuals; companies as a body corporate. The process takes 20–30 minutes.

Step 2: Conduct your ML/TF/PF risk assessment

Before you can write your AML/CTF program, you need to understand your risks. This is a documented assessment of the money laundering, terrorism financing, and proliferation financing risks specific to your agency. You assess four categories:

Customers — types of buyers and sellers you work with (non-residents, investors, complex structures)
Services — transactions you facilitate (unfinanced purchases, off-the-plan, high-value)
Delivery channels — how you work with clients (in-person, remote, online platforms)
Geographic locations — where your clients and transactions come from

AUSTRAC's Program Starter Kit includes a pre-populated risk assessment template for agencies with 15 or fewer staff. It's the fastest way to get started.

April 2026 — Build your program

Step 3: Develop your AML/CTF program

Your risk assessment feeds directly into your program. The program documents your policies, procedures, and controls covering:

Customer identification and verification (CDD)
Ongoing monitoring and enhanced due diligence
Suspicious matter reporting and threshold transaction reporting
Record keeping (7 years minimum)
Training requirements

The AUSTRAC Program Starter Kit provides a customisable program template. You tailor it to your agency's specific circumstances and have it approved by senior management. Once approved, it becomes your AML/CTF program.

For a detailed walkthrough of each program component, see our guide to building your AML/CTF program.

Step 4: Appoint your AML/CTF Compliance Officer

Your compliance officer must be at senior management level — typically the principal or a senior director. They implement the program, oversee training, and are your point of contact with AUSTRAC.

Notify AUSTRAC of your compliance officer by 29 July 2026. Appoint them in April so they have time to get up to speed before obligations commence.

May 2026 — Train your staff

Step 5: Implement employee due diligence

Before any staff member performs AML-relevant duties, you must conduct a background check appropriate to their role — typically reference checks, identity verification, and a criminal history consideration. Document who you checked, what you found, and when.

Step 6: Train all staff

Every person who has AML-relevant duties must be trained before they perform those duties. Training must cover your obligations, how to identify suspicious activity, your CDD procedures, how to escalate concerns internally, and real estate-specific red flags.

It doesn't need to be a formal course — a structured internal session with documented attendance is sufficient for most small agencies. Keep records; you'll need them for your Annual Compliance Report.

June 2026 — Test and verify

Step 7: Test your procedures before the start date

June is your window to run through your CDD process before obligations are live. Walk through your verification workflow: can you collect the required information? Does your record-keeping system capture what's needed?

Check that you can collect full legal name, date of birth, and residential address; verify identity using an acceptable method (in-person document inspection, video call, or electronic verification); screen against the DFAT Consolidated List; and record the outcome with date and method.

Our guide to customer due diligence covers the full verification process in detail.

Step 8: Review your AUSTRAC enrolment

Confirm your enrolment is complete and your compliance officer is listed. Double-check that your business details are current — you must notify AUSTRAC within 14 days of any change to your enrolled details.

From 1 July 2026 — ongoing obligations

When obligations commence, your day-to-day compliance work begins:

CDD on every new client before providing any designated service
Ongoing CDD throughout business relationships — update client information when circumstances change
DFAT and PEP screening at onboarding and periodically thereafter
Threshold Transaction Reports for physical cash of A$10,000 or more (within 10 business days)
Suspicious Matter Reports when you have reasonable grounds to suspect money laundering or terrorism financing (3 business days; 24 hours for terrorism financing)
Annual Compliance Report — your first report covers 1 July to 31 December 2026, due by 31 March 2027

Note on independent evaluations: your first independent program evaluation is not required until at least 1 July 2029 — you have time to mature your program. See AUSTRAC's transitional rules page for the latest phased arrangements.

Start now — it's free

The AUSTRAC Program Starter Kit is free. Our program generator walks you through customising it — no account required. You can complete your risk assessment and draft your program in under an hour.

Start your AML program free — no account needed →

The sooner you start, the more time you have to train staff and test your procedures before 1 July.

AML Simple is a compliance workflow tool, not a provider of legal, financial, or regulatory advice. Using this tool does not guarantee compliance with the AML/CTF Act or any other regulation. You are responsible for ensuring your business meets all regulatory obligations. For professional compliance advice, consider our Expert Advice add-on or consult a qualified AML/CTF professional.