What do I need to do before 1 July 2026?

Quick answer

Real estate agents who facilitate property transactions must be enrolled with AUSTRAC and have a written AML/CTF program in place before 1 July 2026. The full list: enrolment, AML program, CDD process, sanctions and PEP screening, record-keeping, and staff training. AML Simple gets a small agency through the complete sequence in under an hour.

If you want to get this done today rather than read the whole article: sign up at AML Simple, complete the AUSTRAC Enrolment Cheat Sheet (around 5 minutes), then run through the AML/CTF Program Generator (around 15 minutes). Enrolled, documented, ready. The rest of this post explains what you are actually doing and why.

General information only. This article describes regulatory requirements under the AML/CTF Act 2006 (as amended) and AUSTRAC guidance. It is not legal or compliance advice. For guidance specific to your agency, confirm requirements with AUSTRAC or a qualified AML/CTF compliance professional. Information current as of May 2026.

The short version

Under the AML/CTF Act 2006 as amended by the AML/CTF Amendment Act 2024, real estate agencies that facilitate property transactions become reporting entities from 1 July 2026.

Before that date, you need to:

Enrol with AUSTRAC via AUSTRAC Connect
Have a written AML/CTF program approved by senior management
Set up your CDD process for verifying client identities
Set up sanctions and PEP screening for clients
Establish a record-keeping system (7-year retention required)
Train staff who interact with designated services

That is the list. Each item is covered below, with what it involves and how long it takes.

Why 1 July 2026 is the hard deadline

AUSTRAC issued transitional rules in March 2026 that provide limited flexibility for some obligations. The key point: the transitional rules do NOT apply to the AML/CTF program requirement or to enrolment. Those obligations apply from day one.

The program requirement is not a grace period item. From 1 July 2026, providing a designated service without an AML/CTF program in place is a contravention of the Act. Penalties reach up to A$33 million per contravention for a body corporate.

AUSTRAC's approach to newly regulated entities is graduated - they recognise agencies are new to this. But "graduated" means they expect genuine effort and real progress, not a template downloaded the night before. Start now.

The fast path: how to get compliant in under an hour

This is the most efficient route for a small agency with no existing compliance infrastructure.

Step 1: Sign up at AML Simple (2 minutes)

Go to app.amlsimple.com and create an account. Enter your ABN and the platform pulls your registered business details from the Australian Business Register automatically - your agency name, entity type, and registered address are pre-filled. Select which services you provide (the wizard maps these to the Tranche 2 designated service definitions).

Step 2: Enrolment Cheat Sheet (5 minutes)

Open AUSTRAC Connect at connect.austrac.gov.au in one tab. Open the AUSTRAC Enrolment Cheat Sheet inside AML Simple in another tab (it is at /enrolment-cheatsheet). Every field AUSTRAC needs is pre-filled from your account. Copy-paste down the form. Submit.

You are now enrolled with AUSTRAC as a reporting entity.

Step 3: AML/CTF Program Generator (15 minutes)

Run through the AML/CTF Program Generator in AML Simple (at /program/generate). The wizard asks the right questions about your agency - your services, your customer types, how you assess risk. It produces a written AML/CTF program consistent with AUSTRAC's own Program Starter Kit structure.

At the end of this step, you have a program document ready for senior management sign-off.

You are enrolled, your program is built, and your compliance record-keeping has started. That is the hard part done.

The full picture: what each obligation involves

For those who want to understand what they are setting up, here is what each item on the checklist actually means.

1. Enrolment with AUSTRAC

Enrolment is the formal step of registering your agency as a reporting entity with AUSTRAC. It is done once via AUSTRAC Connect. You will need your ABN, your business details, and the names of your designated AML/CTF compliance officers.

This is not an application that AUSTRAC approves or rejects - it is a registration. You enrol and you are enrolled. The obligation to comply begins from the moment you enrol (or from 1 July 2026 if you have not enrolled by then).

What you need: ABN, business address, principal officer details, compliance officer details Time: 10-15 minutes via AUSTRAC Connect (around 5 minutes with the AML Simple Cheat Sheet)

2. AML/CTF program

An AML/CTF program is a written document that shows AUSTRAC how your agency identifies and manages money laundering and terrorism financing risk. It is not a template you download and file away - it is a living document specific to your business.

Under AUSTRAC's guidance, a compliant program for a small real estate agency covers five main components:

Your ML/TF risk assessment
Your CDD policies and procedures
Your staff training procedures
Your independent review process
Your ongoing monitoring and reporting obligations

Each component must reflect your actual agency - your services, your client types, your specific risk factors. AUSTRAC explicitly states that generic template programs that have not been adapted to the business are not compliant.

For a detailed breakdown of what each component requires, read our guide to what goes in an AML/CTF program.

Who approves it: Senior management (the principal, licensee in charge, or equivalent) Time: Around 15 minutes to generate via the Program Generator. Some review time for management sign-off.

3. Customer due diligence (CDD)

CDD means verifying who your clients are before or during a property transaction. At the basic level, this means:

Confirming the client's identity using reliable, independent documents
Understanding the nature of the transaction and the client's purpose
Assessing the risk the client and transaction represent

For most residential sales, standard CDD applies - checking ID documents, verifying name and address. For higher-risk transactions (large cash components, complex ownership structures, overseas parties), enhanced CDD may apply.

CDD obligations apply to clients connected to designated services - primarily buyers and sellers in transactions your agency facilitates.

When: Before or at the time of providing the designated service What to keep: Records of identity documents and verification process, for 7 years

4. Sanctions and PEP screening

Before acting for a client, you need to screen them against:

The DFAT Consolidated Sanctions List (Australian sanctions)
Relevant UNSC sanctions lists
Politically exposed person (PEP) databases

A PEP is someone who holds or has held a prominent public position - government ministers, senior officials, heads of international organisations - and their immediate family members and close associates. PEPs are not automatically suspicious, but they are treated as higher-risk.

Screening is not a one-time check at onboarding. It should be ongoing through the life of the client relationship.

Time: Seconds per client when you have the right tool. AML Simple screens clients automatically against updated lists.

5. Record keeping

You must keep records of your compliance activities for 7 years. This includes:

Client identity verification records
Transaction records for designated services
Your AML/CTF program and any updates to it
Training records
Any suspicious matter reports (SMRs) lodged

Records must be kept in a way that means they can be made available to AUSTRAC within 7 days if requested.

Where: AML Simple stores all compliance records automatically. Data is held in Sydney (ap-southeast-2).

6. Staff training

All staff who provide or are involved in providing designated services must receive AML/CTF training appropriate to their role. For most small agencies, this means the principal and any sales agents handling transactions.

Training does not need to be delivered by an external provider. In-house training that covers the basics - what money laundering looks like in real estate, how to spot a suspicious transaction, what to do if you are concerned - is sufficient for most agencies at this stage.

Minimum: Initial training before staff provide designated services. Ongoing training as your program or the regulatory environment changes.

What happens if you are not ready by 1 July

AUSTRAC's stated approach for newly regulated entities is to focus on education and support in the first period after the laws take effect. They are not expecting perfection from day one.

What they do expect:

That you are enrolled
That you have made a genuine attempt to build a compliant program
That you are taking the obligations seriously

What they do not want to see:

Agencies that have done nothing
Programs that are obviously generic templates with no agency-specific content
Evidence that the obligations have been ignored

If you receive a notice from AUSTRAC or are selected for a review, having documented steps toward compliance - even if the program is still maturing - is materially better than having nothing.

Frequently asked questions

I have not enrolled yet and it is almost July. Is it too late?

No. Enrolment is open now and takes around 10-15 minutes. If you provide designated services, enrol today - do not wait. Use the AML Simple Enrolment Cheat Sheet to make it faster.

Do I need a compliance consultant to write my program?

No. For a small agency providing standard residential sales services, the AUSTRAC Program Starter Kit structure and the AML Simple Program Generator give you everything you need to build a compliant program yourself. Consultants add value for complex situations - large agencies, multiple service types, high-risk clients. For most small agencies, a self-service approach is sufficient.

What does the AML/CTF program actually look like?

A written document, usually 5-15 pages for a small agency, covering the five required components. Not a filing cabinet of policies, not a tick-box exercise. A clear statement of how your agency identifies and manages ML/TF risk. AUSTRAC provides guidance on program structure and a starter kit for real estate agencies.

Is the deadline definitely 1 July 2026? Could it be extended?

Based on current legislation and AUSTRAC guidance, 1 July 2026 is the operative date. There has been no indication from AUSTRAC or the Government that this will be extended. Plan for 1 July.

What if we only do a few sales per year?

Volume does not affect the obligation. If your agency provides designated services - even occasionally - you are a reporting entity and must comply. Your program should be proportionate to your actual risk and volume, but the obligation to have a program exists regardless.

Do I need to tell my clients about AML compliance?

You do not need to explain your AML obligations to clients in detail. You will need to collect identity verification from them as part of CDD. Most clients in 2026 understand this as standard practice - similar to providing ID for a bank account. Keep it matter-of-fact.

The checklist again

Enrol with AUSTRAC via AUSTRAC Connect (or use the AML Simple Enrolment Cheat Sheet)
Build your AML/CTF program (AML Simple Program Generator, around 15 minutes)
Get senior management sign-off on the program
Set up your CDD process for client identity verification
Set up sanctions and PEP screening
Establish record-keeping (7 years, accessible within 7 days)
Complete initial staff training for anyone involved in designated services

That is everything you need before 1 July.

For the full breakdown of what the obligations mean and how they fit together, read our AUSTRAC Tranche 2 complete guide.

What do I need to do before 1 July 2026? AUSTRAC Tranche 2 checklist for real estate agents