Reporting groups: one program across related entities

“Reporting group AUSTRAC” is the search from a group that already has more than one entity: a parent and a practice company, three offices, or a brand used by separately owned firms. A reporting group has a lead entity and members. It can arise because of control, or because the entities elect to form one. It replaces designated business groups. Checked against understanding reporting groups and forming reporting groups on 2 October 2026. This is general information, not legal advice. This page does not reproduce those guides or the quick-reference tables. Who is in the regime at all is /tranche-2.

One program is not one enrolment

Group-wide policies let members share the program, the risk work, and information the group is allowed to share. That is the point of the structure. It is not a waiver. A member still complies with its own policies and with the lead entity’s policies that apply to it. Another member can carry out some of the work, and the entity whose obligation it is remains responsible. Enrolment details are still updated with AUSTRAC. FreeAML does not form the group and does not enrol anyone.

• Lead entity. The entity the group relies on to develop and maintain the group policies. AUSTRAC’s forming page is where eligibility sits. Do not appoint a shelf company that cannot actually do the work.
• Members. Each reporting entity in the group, and, where the rules allow, a business that is not itself a reporting entity. A non-reporting member is not a way to opt a reporting entity out.
• Business group or elective. Control can make a group automatic. Separate owners can elect. You cannot keep half of a business group outside. The forming page is the test. This article does not restate it.

Related offices and a shared brand

Three conveyancing offices trade under one name. Two are owned by the same company. The third is owned by someone who licensed the name. The first two are a control question: if one controls the other, AUSTRAC’s business-group path is the one to read. The third is an elective question: a shared brand is not, by itself, the control test. Read the forming page before you tell the network they are already a group, and before you tell them they cannot be one.

If they do form a group, the program can be group-wide and still differ where the businesses differ. A conveyancing office and a separate accounting company in the same family do not automatically have the same customers or the same designated services. Write the differences. A single PDF with the parent’s letterhead is not those differences.

The bill that repeats with every office

A monthly AML seat quoted once per entity is three seats in a quiet quarter, including the office that opened no new matters. The FreeAML firm suite is A$0 for each entity. There is no monthly seat to multiply by the number of offices. When a matter needs a verification, the firm sends it by email and the check is client-pays. On the public list a personal KYC check is A$20 and a company KYB check is A$40. Confirm the live amounts on FreeAML pricing.

The group program remains the group’s document. A senior manager still approves it. FreeAML stores the checks and the evidence for each firm. It does not replace austrac.gov.au, it does not decide that a franchise is a reporting group, and it does not file the enrolment.

Frequently Asked Questions