From 1 July 2026, real estate agents become reporting entities under the AML/CTF Act. Here's what actually changes, and when.
From 1 July 2026, real estate agents who broker the sale, purchase, or transfer of real estate, or who sell or transfer real estate without an independent agent involved, become reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. That means enrolling with AUSTRAC, running customer due diligence on clients, and reporting certain transactions and suspicious activity, obligations that have never applied to real estate agents in Australia before.
Real estate has historically sat outside Australia's anti-money laundering regime, even though property has long been recognised as a common way to launder proceeds of crime. The reforms referred to as Tranche 2 close that gap by extending the same regime that already applies to banks, casinos, and remittance providers to a second group of businesses, including real estate agents, lawyers, conveyancers, and accountants providing certain services. Enrolment for affected entities opens 31 March 2026, with the new obligations commencing 1 July 2026.
This isn't an optional compliance nice-to-have. The obligations attach directly to specific designated services under the Act, meaning if an agency brokers property sales, it's very likely in scope regardless of size. Getting caught unprepared means building customer due diligence and reporting processes under time pressure right as the obligations commence, at the same time competitors who started early are already compliant and able to say so to vendors and buyers who increasingly ask.
Most agencies are currently in one of two positions: aware Tranche 2 is coming but waiting for closer to the date to act, or not yet aware their day-to-day brokering activity is a designated service under the Act at all. Neither is a safe place to be given enrolment opens 31 March 2026 and the actual obligations start 1 July 2026, leaving a narrow runway to have processes in place.
Start by confirming exactly which of your agency's activities are designated services under the Act, then map that against your actual transaction workflow, from first contact with a buyer or seller through to settlement, to identify where customer due diligence needs to happen and by when. The Act allows customer due diligence to be delayed in certain permitted circumstances for real estate transactions, but only up to a specified point, generally the earlier of 15 days after exchange of contracts or settlement, so agencies need to know exactly where in their process that deadline sits.
Hutly is building AML/CTF compliance directly into the transaction workflow, so customer due diligence, identity verification, and the reporting obligations that come with each designated service happen at the right point automatically, rather than becoming a separate manual process bolted onto an already busy settlement timeline. Sammy tracks where each transaction sits against the compliance deadline and flags what's outstanding before it becomes a problem.
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 whether your agency's activities fall under the real estate designated services in the Act (brokering a sale, purchase, or transfer, or selling/transferring without an independent agent).
Check your enrolment status and timeline against the 31 March 2026 enrolment opening and 1 July 2026 commencement dates.
Map your current transaction process end to end and mark where customer due diligence would need to occur under the new rules.
Identify who in your agency will be designated as the AML/CTF compliance officer, and confirm they meet the eligibility requirements.
Review your systems for capturing and verifying customer identity information consistently across every transaction, not just some.
Enrolment with AUSTRAC opens 31 March 2026, and the new AML/CTF obligations for real estate agents commence 1 July 2026. Agencies should be ready to operate compliantly from that date, not starting to build the process on it.
It applies to agencies providing the designated services set out in the Act, primarily brokering the sale, purchase, or transfer of real estate. Most agencies that broker property sales will be in scope regardless of size.
Under the Act, this covers brokering the sale, purchase, or transfer of real estate on behalf of a customer, and selling or transferring real estate without an independent real estate agent involved.