BAS agent versus designated services
A BAS agent registration does not answer the designated-services question. The practice looks at the work on the file, not at the letters after the principal's name.
Quick answer
Lodging a BAS is a tax job. Forming a company, handling a transaction the program lists, or providing another professional designated service is a different job. The BAS agent credential does not sweep every client into customer due diligence, and it does not leave every client out. Write the services you actually provide, then follow that list.
People search “BAS agent AML Tranche 2” when a regional tax practice is a BAS agent and assumes the registration itself answers Tranche 2. Checked against AUSTRAC's professional designated services page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Bookkeepers have a separate page at AML for bookkeepers. The sector map is /tranche-2.
The credential is not the service
BAS agent AML Tranche 2 searches usually start from the registration, because that is the label on the door. AUSTRAC's question is the designated service. A practice can be a BAS agent and provide no designated service on a given file. The same practice can provide one on the next file, under a different engagement.
Do not split the client base by software. The BAS product and the AML question are different systems. The program names the services. Staff follow the program, not the tax-agent number.
- Read the engagement. A BAS lodgement, a company set-up, and a business sale are not one service because one invoice covered them.
- Keep the tax file separate. Preparing the activity statement does not, by itself, tell you the customer-due-diligence outcome.
- Do not use the title as a pass. Being a BAS agent is not an exemption, and it is not automatic enrolment.
- Write the list down. The services the practice provides belong in the program. A verbal sense of 'mostly BAS' is how a company job gets missed.
Sort the work, not the registration
A sorting aid for a tax practice that is also a BAS agent. This table does not reproduce AUSTRAC's designated-services guidance.
| Work on the file | What you do not assume | What you check |
|---|---|---|
| BAS lodgement only | That the registration creates every obligation | Whether this engagement is a designated service in your program |
| Bookkeeping of past invoices | That history-keeping is the same test | The service you were actually engaged to provide |
| Forming a company for the client | That it is a small extra on the BAS | The professional designated services guidance, then your program |
| A later request to sell the business | That the old BAS file covers the new matter | The new engagement on its own |
Where the BAS-agent page stops
This page is the registration versus the service. It is not the accountant's full designated-services note. That sits on AML for accountants and designated services. This page does not list every item in the Act.
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. Deciding whether a BAS lodgement is a designated service is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not decide which of your BAS-agent services are designated.
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Frequently Asked Questions
List the services, then the BAS work.
The firm suite is A$0. The client pays a check only when the approved program requires one. The BAS registration does not send the link.
Open the Tranche 2 guideQuestions: team@freeaml.com.au