From July 2026, agents brokering a sale have to verify who they're actually dealing with, and prove it. Here's what that looks like in practice.
Customer due diligence, commonly shortened to KYC, means verifying the identity of the person you're dealing with in a real estate transaction, and understanding the nature and purpose of that transaction, before or within a set window of providing the designated service. For real estate agents brokering a sale, this becomes a legal requirement under the AML/CTF Act from 1 July 2026, not a best-practice suggestion.
Identity verification has always mattered in real estate, agents already ask for ID during a sale, but it's mattered for practical reasons, not because failing to do it properly created legal exposure for the agency. The AML/CTF Act changes that. Once an agency is providing a designated service, such as brokering a sale, customer due diligence stops being a courtesy check and becomes a documented obligation with a specific legal basis under section 28 of the Act.
The risk isn't just regulatory. Property remains one of the more attractive ways to move money through the legitimate economy, which is exactly why real estate was brought into scope. An agency that doesn't verify who it's actually transacting with is exposed twice over: to the compliance failure itself, and to the underlying risk that a transaction involving illicit funds runs through the agency without anyone catching it. Getting due diligence right protects the business, not just the paperwork.
Right now, most agencies verify identity informally, a driver's licence sighted at a listing appointment, a passport copy attached to an email, with no consistent standard for what's collected, how it's stored, or when it happens relative to the transaction. That works fine until it has to hold up as evidence that due diligence was actually performed to the standard the Act requires.
Customer due diligence needs to be consistent, timed correctly against the transaction, and provable after the fact. The Act does allow initial due diligence to be delayed in specific permitted circumstances for real estate transactions, but only up to a defined point, generally the earlier of 15 days after exchange of contracts or settlement of the sale. That means agencies need a process that knows exactly where each transaction sits against that deadline, not a filing cabinet of ID copies collected at various points with no structure.
Hutly builds customer due diligence into the transaction itself, capturing and verifying identity at the right point in the workflow, tracking the specified period each transaction has before due diligence is required, and keeping a clear record that due diligence was actually completed. Sammy treats KYC as a workflow step with a deadline attached to it, not a separate manual task someone has to remember to run.
The full breakdown, designated services, CDD timing, reporting obligations, secrecy rules, and a 90-day readiness checklist, cited section by section. Enter your email and it opens straight away.
Standardise what identity information your agency collects for every customer in a brokered transaction, not just some.
Confirm who is responsible for verifying that collected identity documents are genuine and current.
Map the deadline for initial due diligence against your actual transaction timeline (generally the earlier of 15 days after exchange or settlement).
Keep a documented, retrievable record that due diligence was completed for every transaction, not just the ones that raised a concern.
Train front-line agents on what to collect at first contact with a buyer or seller, since that's usually the earliest practical point to start.
In practice, yes. Know Your Customer (KYC) is the common industry shorthand for the identity verification and due diligence obligations set out formally in the AML/CTF Act as customer due diligence.
In certain permitted circumstances, real estate transactions can have delayed initial customer due diligence, but only up to a specified deadline, generally the earlier of 15 days after exchange of contracts or settlement. It isn't unlimited.
It applies to the reporting entity providing the designated service, typically the agency brokering the sale, and the individuals within it who carry out the customer-facing part of the transaction.