A practical readiness checklist for the AML/CTF obligations coming to real estate agents on 1 July 2026, not just a summary of the legislation.
A real AUSTRAC readiness checklist for a real estate agency covers five things: confirming you're in scope, enrolling with AUSTRAC, appointing an AML/CTF compliance officer, building a customer due diligence process with clear timing, and setting up the reporting obligations (suspicious matter and threshold transaction reports) that come with being a reporting entity.
Generic compliance checklists for this topic tend to summarise the legislation rather than translate it into what an agency actually has to do, in what order, before 1 July 2026. That's understandable, since the reforms are new, but it leaves agencies with a list of legal concepts and no clear sequence of actions to actually get ready.
Agencies that leave AML/CTF readiness until closer to the July 2026 commencement date will be building enrolment, compliance officer designation, and due diligence processes under time pressure, at exactly the point their transaction volume doesn't slow down to accommodate it. Agencies that treat this the same way they treat any other major compliance shift, methodically and early, avoid that crunch entirely.
Most agencies are currently either waiting for clearer industry guidance before acting, or assuming their existing identity-checking habits at listing appointments already cover what's required. Neither closes the actual gap: enrolment has a specific opening date, a compliance officer has specific eligibility requirements, and due diligence has a specific legal basis and timing that informal habits don't meet.
Work through readiness in the same order the obligations actually apply: confirm scope, enrol, appoint a compliance officer, build the due diligence process, then build the reporting process. Each step depends on the one before it, so tackling them out of order (like trying to design reporting processes before confirming who's actually accountable as compliance officer) creates rework.
Hutly is building AUSTRAC readiness into the agency workflow itself, so due diligence, identity verification, and the reporting obligations that follow from each designated service happen as part of the transaction rather than as a bolt-on compliance exercise. Sammy tracks each transaction against the relevant deadlines and keeps the record an agency would need to show it met its obligations.
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.
Confirm which of your agency's services are designated services under the AML/CTF Act (primarily brokering a sale, purchase, or transfer of real estate).
Register your enrolment intent ahead of the 31 March 2026 enrolment opening, so you're not starting from zero when the window opens.
Designate an AML/CTF compliance officer who meets the eligibility requirements set out in the Act, and confirm that appointment is documented.
Build a customer due diligence process with a clear point in your transaction workflow where identity verification happens, and a fallback for the permitted delayed-due-diligence circumstances.
Set up a process for suspicious matter reports and threshold transaction reports, including who in the agency is responsible for identifying and lodging them with AUSTRAC.
Review this checklist again closer to 1 July 2026, since AUSTRAC guidance and starter kits are still being finalised in the lead-up to commencement.
Confirm whether your agency's actual activities meet the definition of a designated service under the Act. Everything else, enrolment, compliance officer appointment, due diligence process, follows from that.
AUSTRAC guidance and starter kits for Tranche 2 entities are still being finalised in the lead-up to the 1 July 2026 commencement. Agencies shouldn't wait for that to start on the parts they can control now, like appointing a compliance officer and mapping their transaction process.
Yes. The requirement to designate an eligible AML/CTF compliance officer applies to reporting entities generally, not just larger agencies. The role can sit with an existing team member as long as they meet the eligibility requirements.