Tranche 2 is here: what it means for Australian real estate agencies

The rules changed on 1 July 2026

Australia's anti-money laundering and counter-terrorism financing (AML/CTF) regime expanded on 1 July 2026 to cover a new group of businesses, often called “Tranche 2” entities. Real estate agents, alongside lawyers, conveyancers, accountants and dealers in precious metals and stones, are now captured when they provide certain services.

This is a genuine shift. If your agency provides in-scope services, you are now a reporting entity with ongoing obligations to AUSTRAC — not a one-off registration.

What counts as a “designated service”

Capture is based on the services you provide, not simply on being a real estate agency. You are likely captured if you buy, sell or manage the transfer of real estate for a client, or act as a real estate agent in a sale. Broadly transactional work of this kind falls within the regime.

Some activities generally sit outside it — for example, pure property management and leasing that does not involve the sale or transfer of real estate. The right question is never “are real estate agents captured?” but “which of the services we provide are designated services?”

The enrolment deadline has passed

Enrolment with AUSTRAC opened on 31 March 2026, and businesses providing designated services were required to be enrolled by 29 July 2026. That date has now passed.

Importantly, the obligations themselves apply from 1 July 2026 regardless of whether a business has enrolled. If your agency is providing designated services and has not yet enrolled, the priority is to enrol without further delay and stand up the rest of your program.

What a compliant agency needs in place

Beyond enrolment, the regime expects you to build and run an AML/CTF program. In practice that means:

• A risk assessment of the money-laundering and terrorism-financing risks your agency faces.
• A documented AML/CTF program, approved by senior management and overseen by your governing body.
• An appointed AML/CTF compliance officer.
• Customer due diligence — knowing who your clients are and verifying their identity.
• Ongoing monitoring and reporting of suspicious matters to AUSTRAC.
• Records kept, for most obligations, for seven years.

None of this is a single document you file and forget. It is an operating capability you need to be able to evidence at any time.

If you're behind, start here

If the 29 July date caught your agency out, you are not alone, and the practical path forward is straightforward: enrol, complete a risk assessment, put a program and a compliance officer in place, and get customer due diligence and record-keeping running on live matters. True Comply gives you the program, the screening and the audit-ready evidence to back every decision — expert-led, delivered by technology. If you're not sure where you stand, start the conversation and we'll help you confirm it.