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Compliance
October 4, 20269 min read

Exemption application: when it is worth it

An exemption application is worth the work only when a lawyer has a specific ground and the firm can keep operating lawfully while it waits. It is not a substitute for enrolment if you provide a designated service.

Quick answer

Most suburban firms will not get a shortcut by filing something and pausing the program. If you clearly provide a designated service, enrol and write a program, and if you are unsure of scope, do the designated-services test first. Silence is not an exemption. This page does not list the grounds or predict an outcome.

People search “apply for AUSTRAC exemption” when a law firm is asked whether an exemption application is easier than enrolment for a client that probably provides a designated service. Checked against AUSTRAC's page on who and what we regulate on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Whether you are a reporting entity is what a reporting entity is. The sector map is /tranche-2.

A specific ground, or the ordinary path

Apply for AUSTRAC exemption is a search from firms that hope a form will beat the start date. An exemption is a decision AUSTRAC makes, not a status you claim by posting a letter. If the business provides a designated service, the ordinary path is to enrol and to run a program. Waiting to see is not an application, and it is not a defence.

A narrow activity that may sit outside the Act is a different conversation, and it is a lawyer's conversation about that activity. It is not a letter that covers the whole firm. This page does not set out grounds, fees, or chances. Inventing them would be a guess.

  • Start with the service. If a designated service is clear, do not file an application as a way to skip enrolment.
  • If you are unsure, test scope first. The reporting-entity question comes before a form. An exemption is not how you find out.
  • Keep the ground narrow. Advice about one activity is not a shield for every other service the firm provides.
  • Keep operating lawfully while you wait. An unlodged hope does not pause the obligations that already apply.

When the form is the wrong tool

A sorting aid before anyone drafts an exemption. This table does not reproduce AUSTRAC's regulatory scope.

SituationWorth a lawyer's lookNot a shortcut
You clearly provide a designated serviceEnrolment and a program are the ordinary pathAn application filed to avoid the start date
You are unsure you are in scopeThe designated-services test, firstAn exemption form used as a maybe
One narrow activity may sit outsideAdvice on that activity onlyA letter that covers the whole firm
You want to wait and seeNot an application at allSilence treated as an exemption

Where the exemption page stops

This page is when an application is the wrong first step. It is not a compliance plan. How a firm that is in scope actually complies sits on how to comply with Tranche 2. This page does not state the grounds for an exemption.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Preparing an exemption application is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not apply for an exemption for you, or tell you that a ground will succeed.

Frequently Asked Questions

Test the service before you draft an application.

The firm suite is A$0. The client pays a check only when the approved program requires one. An exemption form is not that program.

Open the Tranche 2 guide

Questions: team@freeaml.com.au