Accountant forms a company: CDD before ASIC lodgement

People search “company registration AML CDD timing” when a tax practice is ready to lodge the company form and plans to verify the owners after the ACN exists. 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. Work before a service starts is pre-commencement customer AML. Where a delay can exist at all is delayed initial CDD. The sector map is /tranche-2.

Lodgement is the service, not the receipt

Company registration AML CDD timing is a before-and-after problem. The designated service, if your program classifies formation that way, is you forming the company. That happens when you prepare and lodge the application. The ACN is ASIC's response, and using the ACN as the starter's gun means you have already provided the service.

The customers are the people you are doing this for, including who will own and control the company. You do not need the ACN to know who those people are. They are in the instructions.

• Put due diligence before lodgement. The link goes to the client while you can still stop.
• Do not wait for the ACN. The number confirms a company exists. It does not start your obligation.
• A delay must already be in the program. Settlement-style pressure on a formation is not a new exception.
• Individuals are not inside the company check. The company and the people are separate verifications.

The afternoon of a formation

A tax practice can lay the afternoon out in order. Instructions, due diligence, then lodgement. Reversing the last two is the mistake this page is about. If a permitted delay applies, the file should cite the program, not the fact that ASIC's form was open.

Where the lodgement page stops

This page is the timing against lodgement. It is not the test of whether formation is a designated service for your firm. That classification is on designated services for accountants.

Permitted delay, if your facts actually fit one, is delayed initial CDD. Do not build a delay on this page.

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. The ASIC fee is not the KYB fee, and the ACN does not include the individuals' checks. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that company formation is a designated service or time the lodgement for you.

Frequently Asked Questions