Advertising a service is not the enrolment clock

Firms add “AUSTRAC enrolled” or a list of services to a website before the first job exists, and then ask if the advertisement itself created the duty. Checked against AUSTRAC's enrolment overview on 5 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The 28-day rule is enrol within 28 days. The date for businesses already providing the new services is 29 July 2026. How to tell a service from ordinary work is designated services. The sector map is /tranche-2.

What the enrolment page uses as the clock

AUSTRAC says that if you provide a designated service with a geographical link to Australia you must enrol. You must apply no later than 28 days after the day you start providing a designated service. For the new designated services that commenced on 1 July 2026, you must apply by 29 July 2026 if you provide any of them. The verbs are provide and start. They are not “mention on a website” and they are not “hope to offer next year”. A firm with a true zero, no instructions and no preparatory work, is not on the 28-day clock described on that page.

Zero is rarer than partners think. AUSTRAC's professional services guidance treats some preparation as the service. Drafting documents to appoint a person as a company secretary for a nominator, or identifying someone for that role, can already be item 7. A seller's agent starts the designated service to the seller when the agency agreement is signed, which can be before a buyer exists. “No clients yet” is the wrong sentence if an agreement is signed or a draft appointment is in the matter. Read the start-line for the item you advertised. If you have crossed it, enrol within 28 days of that day, not within 28 days of the website going live.

Enrolling early, and enrolling by mistake

• You may enrol before the first job if you know the service is about to be real. AUSTRAC told newly regulated businesses not to wait until the last day.
• Do not enrol to decorate a proposal. While you are on the Reporting Entities Roll you have obligations. AUSTRAC names the annual compliance report as one that continues.
• If you enrolled and you do not provide a designated service, apply in writing, through AUSTRAC Online, to be removed. The enrolment page says you can.
• Update the enrolment within 14 days if the services you do provide change. An advertisement that becomes a real service is a change worth recording once it is real.
• Customer due diligence still waits for a customer. Enrolment does not create a check with nobody to check. It also does not excuse a check once the service starts.

Where this page stops

This page is the empty pipeline. The form, once you do provide the service, is the AUSTRAC enrolment form guide.

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 charge you to be enrolled, and it does not enrol you. A check is client-pays when a customer exists.

Frequently Asked Questions