What AUSTRAC Tranche 2 means for real estate agents

You've probably heard the phrase "AUSTRAC Tranche 2" at a franchise conference, from your accountant, or in a trade newsletter. Maybe you've Googled it once, landed on some legislation, and closed the tab. That's fair — the source material is dense.

This post is the plain-English version. By the end, you'll know whether these new laws apply to your agency, what you'll need to do, and when.

What is AUSTRAC Tranche 2?

AUSTRAC is Australia's financial intelligence agency. It has regulated banks, casinos, and money transfer businesses for years under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006.

For most of that time, real estate agents were left out. That changed in late 2024, when the AML/CTF Amendment Bill passed Parliament in November 2024 and was enacted in December, extending the AML/CTF regime to a new group of industries — the so-called "Tranche 2" sectors.

Tranche 2 covers real estate agents, lawyers, accountants, and dealers in precious metals and stones. Australia was one of the last FATF member countries to bring these sectors into scope; the legislation had been delayed for 17 years. It is now law.

Does this apply to your agency?

The obligations apply if your agency provides what the law calls a designated service. For real estate, the key designated service is:

Brokering the purchase, sale, or transfer of real estate for other people as part of a business.

In practice, this means:

Selling agent or buyer's agent — you're covered. Most real estate agencies fall here.
Property developer — if you sell or transfer real estate directly (without an independent agent), you're also covered.
Auctioneer — if you conduct sales of real estate, you're covered.

What's NOT covered

This is where it gets important for agencies with mixed operations.

Property management, leasing, and rental management are not designated services. If your agency manages rental properties, handles lease renewals, or coordinates tenancy applications — none of that triggers AML/CTF obligations under Tranche 2.

An agency that only manages rentals (no sales at all) is not regulated.

If your agency does both — sales and property management — only the sales side is in scope. Your property management arm doesn't create additional obligations under this legislation.

Note: other designated service categories exist, such as conveyancing services. This post focuses on real estate agents. For the full picture, see AUSTRAC's real estate guidance or use the AUSTRAC Reform Checker to confirm your position.

The key dates

| Date | What happens | |---|---| | 31 March 2026 | Enrolment with AUSTRAC opens. New rules take effect for existing reporting entities. | | 1 July 2026 | AML/CTF obligations commence for all Tranche 2 entities, including real estate agents. | | 29 July 2026 | Deadline to complete your AUSTRAC enrolment. | | 1 Jan – 31 Mar 2027 | First Annual Compliance Report period (covering July–December 2026). |

AUSTRAC has confirmed there will be no deadline extension. The July 2026 date is firm.

What does a typical small agency need to do?

Let's say you run a three-person agency in suburban Melbourne. You handle both sales and property management. You've never had to think about money laundering before.

Here's what the new laws require — before 1 July 2026, key steps include:

Enrol with AUSTRAC via AUSTRAC Online (opens 31 March 2026). You have until 29 July 2026 to complete this, but don't leave it to the last week.
Conduct a risk assessment — document the money laundering and terrorism financing risks specific to your business. Think about the types of clients you deal with, the properties you sell, and where your clients' funds come from.
Develop an AML/CTF program — written policies and procedures covering how you'll identify clients, verify their identity, and report suspicious activity. AUSTRAC has published a free Program Starter Kit for agencies with 15 or fewer staff providing one designated service — it's a solid starting point for smaller agencies.
Appoint a compliance officer — someone at senior management level responsible for your program. In a small agency, this is often the principal. AUSTRAC must be notified of who this is by 29 July 2026.
Train your staff — everyone involved in property transactions needs AML/CTF awareness training before they start performing those duties.

Once 1 July 2026 arrives, your obligations include verifying the identity of clients before a transaction, screening for sanctions and politically exposed persons, and filing reports with AUSTRAC when required.

Is this just for big agencies?

No — and this is worth saying clearly. These obligations apply regardless of agency size. A sole trader running a buyer's agency has the same legal requirements as a 50-person franchise network, though the scale of what you implement can be proportionate to your risk.

The government's estimated upfront compliance cost is around A$28,650 per business, with ongoing costs of approximately A$23,250 per year. Those figures are from the government's own regulatory impact assessment, and they assume building compliance processes from scratch without tooling.

For a three-person suburban agency, the biggest challenge isn't complexity — it's finding the time to get it done before the deadline.

What to do now

If you're a real estate agency principal who brokers property sales, start here:

Confirm you're in scope using AUSTRAC's Reform Checker
Read AUSTRAC's real estate guidance at austrac.gov.au
Start building your program — AUSTRAC's free Starter Kit is the right entry point for small agencies
Get your systems ready — you'll need a way to collect and record client identity information before you can conduct transactions from 1 July

AML Simple is built to help small agencies do exactly this — without needing a dedicated compliance team or a law firm on retainer. You can start your AML program today, no account needed.

Start your AML program free — no account needed →

AML Simple is a compliance workflow tool, not a provider of legal or regulatory advice. The information in this post is general in nature and reflects our understanding of AUSTRAC's published guidance as at March 2026. Your obligations may differ based on your specific circumstances — consult a qualified compliance professional for advice tailored to your agency. See our Expert Advice service if you need professional guidance.