A company secretary role can be a designated service

Accountants and company-service businesses ask this because “company secretary” is an ordinary ASIC form and an AML designated service is not. Checked against AUSTRAC's professional designated services on 5 October 2026. The page was last updated on 3 September 2026. This is general information, not legal advice. This page does not reproduce that guidance. The table as a whole is table 6 designated services. Accountants' services are designated services for accountants. A different in-house role is in-house counsel. The sector map is /tranche-2.

What item 7 covers

AUSTRAC's table says item 7 is acting as, or arranging for another person to act as, any of a list of offices, on behalf of a person called the nominator, in the course of carrying on a business. The list includes a director or secretary of a company, a power of attorney of a body corporate or legal arrangement, a partner in a partnership, a trustee of an express trust, and a functionally equivalent position. It does not apply in a circumstance covered by subsection 6(5E). The customer is the nominator. AUSTRAC says you are providing the service when you act in those roles for a nominator, and also when you are preparing: coming to an agreement that a person will act, drafting the appointment, or identifying someone to be appointed.

Preparation matters because firms say they have not “started” until ASIC is updated. AUSTRAC's page says the designated service includes making preparations. A draft appointment, or an introduction of a person who will be secretary for the client, can already be the service. Customer due diligence on the nominator belongs before that, unless a delay rule that truly applies says otherwise. If the nominator is a company or a trust, the check is KYB, and you still identify the people the program names. If the nominator is a person, the check is KYC. The company that ends up with a secretary is not a reason to skip the nominator.

What item 7 is not trying to catch

AUSTRAC says an agency or service-provider relationship, by itself, does not mean the person is in one of the item 7 roles. A filing agent, nominee or representative who only does administrative steps does not, by that fact alone, fall inside item 7. The page says item 7 is not intended to capture ordinary agent-principal relationships where the person acts on instructions without assuming control, authority or fiduciary responsibility equivalent to the listed positions. It also lists situations the designated service does not apply to, including a power of attorney for an individual, trustees of testamentary trusts, trustees of trusts not created in writing, and acting in a fiduciary capacity because of a court or tribunal order. Those exclusions are reasons to read the page, not reasons to wave through a firm that clearly sits as secretary for a client's company.

An employee who is company secretary of the company that employs them is the case partners worry about, and it is not the case the item is written around. The item is “on behalf of a nominator”, in the course of a business of providing that service. This page does not rule that every employed secretary is outside, because subsection 6(5E) is the exception in the Act and this page does not reproduce it. If you are unsure, read the subsection against the engagement letter. Do not use a blog to close a borderline appointment.

• Nominator first. That is the customer AUSTRAC names. Know them.
• Arranging counts. Finding a secretary for a client can be the service, not only being the secretary.
• Preparation counts. Drafting the appointment can be the start.
• Administrative filing alone may not. AUSTRAC says a mere filing agent is not, by that fact, inside item 7.
• Subsection 6(5E). There is an exception. Read it. This article does not restate it.

Where this page stops

This page is the secretary role. It is not every professional service in table 6. The wider list is table 6 designated services.

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. There is no subscription. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that an appointment is item 7. If you do run a check on the nominator, the client pays. A company nominator is KYB.

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