Reporting entity Australia: what it means if only some work is regulated
Reporting entity Australia is a service test. If only some work is regulated, customer due diligence sits on that work.
Quick answer
A reporting entity in Australia is the person or business that provides a designated service with a geographical link to Australia. The status follows the service, not the whole practice. If only some work is regulated, customer due diligence sits on those matters. FreeAML is for those matters. The firm suite is A$0 and verification is client-pays.
A search for “reporting entity australia” often assumes the whole firm flipped on 1 July 2026. It did not. AUSTRAC’s glossary calls a reporting entity an entity that provides a designated service under section 6 of the AML/CTF Act. The longer note is who and what AUSTRAC regulates. The Department of Home Affairs describes the same model on what it means to be regulated. Checked on 2 October 2026. This is general information, not legal advice. This page does not reproduce those pages. The sector map is /tranche-2.
The service makes the entity
You are a reporting entity because of a designated service, not because the sign says lawyer, accountant, agent, or dealer. AUSTRAC also says the geographical link has to be met, and that providing a service only now and then can still be carrying on a business. Read that test on their page before you treat a one-off file as out. This article does not restate it.
Partial regulation in one practice. The row is a sorting aid. It does not decide the file.
| Work on the desk | Usually | What still happens |
|---|---|---|
| A designated service, such as a transfer, a company formation, or a sale of the entity | In, if the other conditions on AUSTRAC’s page are met | Enrolment covers the firm. Customer due diligence covers this matter |
| A will, a tax return, or ordinary bookkeeping | Often outside | No check, unless this engagement is actually a designated service |
| A mix in the same week | The firm can be a reporting entity and still have quiet files | Tooling follows the in-scope matter only |
Home Affairs makes the same cut in public: not every business in a sector is regulated, and the obligations need not cover every service the business offers. They cover the designated services. The professional list is Table 6 designated services. The order of questions is the designated services decision tree.
Enrolment is not “every client”
If you provide a designated service, you enrol. AUSTRAC’s enrolment overview is the date and the form. Newly regulated businesses that start the new services on 1 July 2026 are told to apply to enrol by 29 July 2026. Confirm that date on the page before you diary it. Registration is a further step, and AUSTRAC says lawyers, accountants, real estate agents, conveyancers, and dealers in precious metals and stones generally do not take it. Remittance and virtual-asset providers do. This page does not reproduce that overview.
Enrolment does not mean a passport from every email address. Initial customer due diligence sits on the designated service. The requirement is customer due diligence requirements. The writing that has to exist before you start is what Tranche 2 firms put in an AML/CTF program.
Tooling for the designated matters only
A practice with ten quiet files and one transfer still needs a way to verify the transfer. It does not need a check on the ten. On FreeAML the firm suite is A$0, including in a month when no new matter is in scope. When a designated matter does need a check, the firm emails the client. 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. Confirm the live amounts on FreeAML pricing. The path is /aml-check.
A group of related entities is a different question. Sharing one program across letterheads is a reporting group. That structure does not switch off each entity’s own duties, and it does not pull an out-of-scope file into customer due diligence. FreeAML does not decide that a service is designated, does not enrol the firm, and does not lodge in place of the compliance officer.
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Frequently Asked Questions
Verify the designated matter only.
The firm suite is A$0. The client pays by email when the program says the file is in.
Start an AML checkQuestions: team@freeaml.com.au