AML/CTF Rules 2025: Enrolment for real estate sector

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Understanding AML/CTF Rules 2025 Part 3 Enrolment, and what it means for the real estate sector

From 31 March 2026, real estate agencies that provide designated services such as handling property sales or managing trust accounts must enrol with AUSTRAC as reporting entities. Enrolment is a legal requirement under Australia’s expanded AML/CTF regime (Tranche 2) and agencies cannot provide these services without it.

The enrolment process confirms your agency’s structure, ownership, and the services you provide, giving AUSTRAC visibility over who controls client money and how risks are managed. Real estate groups with franchises, trust accounts, or cross-border dealings will face additional complexity, making early preparation essential.

This guide explains what AUSTRAC requires when you enrol, why it matters for agencies, and practical steps to streamline the process ahead of the 29 July 2026 deadline.

What enrolment means

From 31 March 2026, real estate agencies that provide designated services (mainly handling property sales and managing trust accounts) must enrol with AUSTRAC as reporting entities. Enrolment registers your agency so you can legally provide those services.

Enrolment for tranche 2 entities opens on 31 March 2026 and you must be enrolled by 29 July 2026.

What AUSTRAC needs to know

When enrolling, agencies must provide:

• Designated services: which services you provide or plan to provide, including start dates and whether they are delivered in Australia or overseas.
• Business structure and professional associations: company, partnership, trust, or association. Include professional memberships (e.g. REIA).
• Control: beneficial ownership, directors or partners and contact details
• Scale: staff numbers, annual turnover, and whether you qualify as a small business.
• Reporting groups: confirmation if you are part of a reporting group and whether you are the lead. If you’re not the lead, then state who is.

Extra details for certain types of organisations

Beyond the basics, AUSTRAC also asks for extra details based on your firm’s legal structure. The common thread is the same: they want clarity on who controls and makes decisions in the organisation.

• Partnerships: details of individual partners who make key decisions (names, addresses, DOBs, government IDs) or, if partners are companies, trusts or associations, their equivalent details.
• Companies: names and dates of birth of directors, director IDs, where you’re incorporated or registered and overseas business addresses. If you have a parent company, you’ll need its name, address, country of residence and identifier.
• Trusts: type of trust, former names, and details of all trustees (individual or corporate).
• Associations or co-operatives: details of the main decision-makers (names, addresses, DOBs, government IDs).

Why this matters for agencies

• Franchise groups: The franchisor or master franchisee may need to act as lead, collating details across offices.
• Trust accounts: AUSTRAC requires clarity on who controls client money. Agencies running rent or bond accounts must provide trust and trustee details.
• Frequent churn: Staff and ownership turnover is higher in real estate than in law or accounting. Every new director, partner, or trustee appointment can trigger an update obligation.
• Revenue reporting: Large franchise groups may need to provide combined earnings data if above $100m.
• Multiple licences, one brand: Some groups hold sales, property management, and buyers’ agency licences in different entities. AUSTRAC will expect enrolment for each legal entity, not just the trading name.
• Cross-border operations: Agencies handling clients or properties overseas (e.g. offshore buyers) must declare whether services are provided in Australia, offshore, or both - an easy detail to overlook.
• Agency principals on the hook: Even if day-to-day trust account management is delegated, AUSTRAC wants the names and IDs of the principals who hold ultimate responsibility.
• Hidden service arms: Some agencies run side businesses (mortgage broking, buyers’ advocacy, strata management). If these involve designated services, they must be declared.

Tips for enrolling smoothly

• Map your services: Identify which parts of your practice involve designated services (conveyancing, managing trust funds, complex corporate transactions).
• Collect the information: Gather partner or director details, including dates of birth and government IDs.
• Create an internal register: Set up a central register for governance and ownership details so you’re not scrambling across multiple spreadsheets every time AUSTRAC needs an update.
• Check structures: Define the firm’s structure before filling in the enrolment form.
• Nominate an enrolment officer: Decide who in the firm will complete and declare the enrolment.
• Plan for updates: Put systems in place to update AUSTRAC whenever partners change, services expand, or contact details shift.
• Check twice: Errors in information will slow you down.
• Use support: AUSTRAC’s helpdesk and FAQs are extensive
• Call in experts if needed: A compliance adviser can save time (and stress)
• Avoid peak times: Test the system off-peak to iron out glitches.
• Enrol early: ~90,000 companies need to register and AUSTRAC's systems will be under strain. Submitting your enrollment early gives you time to resolve any issues that may arise.

Immediate next steps

• Map your services and confirm which trigger enrolment.
• Franchise heads: coordinate with franchisees on enrolment strategy.
• Gather corporate and governance information for AUSTRAC.
• Prepare to update enrolment after structural changes.
• Seek advice to align franchise agreements with AUSTRAC’s requirements.