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October 4, 20269 min read

Migration agent is not automatically a reporting entity

A migration agent is not automatically a reporting entity. Lodging visas is not, by itself, a designated service under Tranche 2.

Quick answer

The test is the service, not the registration as a migration agent. Ordinary visa work does not enrol the practice. If the same person also provides a designated legal, accounting, or other service, that service is a separate question. This page does not reproduce the designated-services list and does not clear a mixed practice.

People search “migration agent AML Tranche 2” when a migration agent hears about Tranche 2 and assumes visa lodgements make them a reporting entity. Checked against AUSTRAC’s page on who and what it regulates on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The reporting-entity definition is what a reporting entity is. The service test is the designated services decision tree. The sector map is /tranche-2.

The registration is not the service

Migration agent AML Tranche 2 is often a frightened search. The agent is registered, advertises immigration advice, and has heard that new professions must enrol. Registration with the migration authority is not the AML/CTF test. A reporting entity provides a designated service; visa lodgement and immigration advice are not, by their labels, on that list.

The caution is the mixed practice. Some agents are also lawyers. Some prepare work that crosses into a designated accounting or legal service. Those services are tested on their own; this page does not reproduce AUSTRAC’s list and does not give a mixed practice a pass; if the only work is migration advice, do not enrol because a headline said every adviser is in; if there is another service, walk the decision tree.

  • Start from the work. Write what the client paid you to do. A visa file is not a designated service by its cover sheet.
  • Ignore the job title. Migration agent is a registration. Reporting entity is a services test.
  • Split a mixed practice. A legal designated service does not hide inside an immigration brand, and an immigration brand does not create one.
  • Do not enrol from a headline. Enrol when you provide a designated service. Do not enrol because a neighbouring profession must.

Visa work beside other work

Sorting a migration practice. This table does not reproduce AUSTRAC’s designated services.

WorkAutomatic reporting entity?Next step
Visa lodgement and immigration adviceNoKeep it separate from other services
The same person, also a legal designated serviceNot automatic, but not ignoredTest that legal service
Company formations or a designated accounting serviceNot answered by the migration registrationUse the decision tree
Membership of an agent bodyNoMembership is not enrolment

Where this page stops

This page is the automatic-enrolment myth. It is not the full services list. That list is discussed on AML/CTF 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. Use KYB when the customer is a company or a trust. Deciding whether a migration practice provides a designated service is not included in the firm suite. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a migration practice is a reporting entity.

Frequently Asked Questions

Test the service you actually provide.

The firm suite is A$0. The client pays a check only when an approved program requires one.

Open the Tranche 2 guide

Questions: team@freeaml.com.au