You missed the 29 July enrolment deadline. What now?

First, the honest position

Enrolment with AUSTRAC opened on 31 March 2026 and businesses providing designated services were required to be enrolled by 29 July 2026. If you have not enrolled, you are late, and the obligations have applied since 1 July 2026 whether or not you enrolled.

Failure to enrol can attract civil penalties, and they are structured to accrue for each day the contravention continues. That is the reason speed matters here in a way it does not with most compliance tasks: the exposure is not fixed, it grows.

Do these things in this order

• Confirm you are actually captured. Check which of your service lines are designated services before you enrol — enrolling unnecessarily creates obligations you may not have.
• Enrol with AUSTRAC. It is the single highest-value action and it stops the clock on that particular contravention.
• Notify your AML/CTF compliance officer. Newly regulated entities must notify AUSTRAC of the appointed compliance officer by the later of 29 July 2026 or 14 days after enrolling.
• Complete a risk assessment. It is the foundation the rest of the program is built on and it does not have to be elaborate to be adequate.
• Document the program and get senior management approval.
• Start customer due diligence on live matters immediately, then work backwards through existing relationships.

Do not backdate anything

The instinct when you are behind is to make the paperwork look as though it was always there. Resist it. A program dated honestly, with a clear record of when you identified the gap and what you did about it, is a far better position than a document that does not survive scrutiny.

Regulators generally distinguish between a business that got it wrong and fixed it, and one that tried to conceal it. The second is a different category of problem.

What good looks like from here

Being late is recoverable. What is much harder to recover from is being late, staying late, and having no record of trying. Enrol, build the program, start running due diligence on real matters, and keep the evidence as you go — so that if anyone asks, the answer is a record rather than an explanation.

True Comply is built for exactly this: standing up a working program quickly and capturing the evidence from day one. If you are behind and want a clear path back, start the conversation.