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5 October 20268 min read

Tranche 1 was already in. Tranche 2 started on 1 July 2026

Tranche 1 is the common name for businesses that were already reporting entities, such as banks. Their updated obligations started on 31 March 2026. Tranche 2 is the common name for the newly regulated services, including real estate, conveyancing, legal, accounting, and precious metals and stones, which started on 1 July 2026. Newly regulated businesses that provide those services enrol by 29 July 2026, or within 28 days of starting if they start later.

Quick answer

Tranche 1: you were already a reporting entity, and the updated duties date from 31 March 2026. Tranche 2: your designated service is one of the new ones, and it commenced on 1 July 2026. Enrolment for those new services was due by 29 July 2026 if you were already providing them.

The two labels are how the industry talks. The dates are how AUSTRAC and the OAIC talk. Checked against AUSTRAC's article on changes to AML/CTF obligations and AUSTRAC's β€œnew reporting regime now in force” article, both published 1 July 2026, AUSTRAC's enrolment overview, and the OAIC reporting-entity guidance updated 28 August 2026, all read on 5 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The plain account of the new services is what Tranche 2 is. The July date is 1 July 2026. The enrolment date is 29 July 2026. The sector map is /tranche-2.

Who was already in

The OAIC calls current reporting entities Tranche 1. AUSTRAC and the OAIC both date the updated obligations for those existing reporting entities to 31 March 2026. Those businesses include the financial services, gambling, bullion and remittance businesses that have lived with the Act for years. Banks are the example clients notice, because the bank's questions arrived long before a conveyancer mentioned AUSTRAC. Their program was updated. It was not created from nothing in July.

If you are in that group, your question is whether your program, your officer and your customer due diligence match the reformed rules from 31 March 2026. It is not whether you β€œopt in” to Tranche 2. Some businesses can provide both an old designated service and a new one. Read the service. Do not pick a tranche because the training room used one slide.

Who came in on 1 July 2026

AUSTRAC's 1 July 2026 article said thousands more businesses were now regulated, including real estate, conveyancing, legal services, accounting, and precious stones and metals. It said they must have a program, conduct customer due diligence, report suspicious matters and keep records, and that newly regulated businesses must enrol by 29 July 2026. The enrolment page adds the standing rule: apply no later than 28 days after the day you start providing a designated service, and enrol by 29 July 2026 if you provide any of the new designated services that commenced on 1 July 2026. Most of those businesses enrol only. Registration is the extra step AUSTRAC describes for remittance and certain virtual asset services, not for a typical law firm, accountancy, agency or conveyancer.

  • Use the date that matches the service. 31 March 2026 for the updated duties of existing reporting entities. 1 July 2026 for the new services. 29 July 2026 for enrolment of businesses providing those new services.
  • Do not borrow the bank's pack. A Tranche 1 program is not a Tranche 2 program with the logo swapped.
  • Do not enrol a private seller. Providing a designated service is the test. Buying a house is not.
  • Customer due diligence is yours. The bank's questions do not fill your file.
  • One price list either way. The client's check does not get a tranche surcharge.

The labels and the dates published by AUSTRAC and the OAIC. This table does not reproduce their pages.

LabelWho people meanDate to remember
Tranche 1Existing reporting entities, such as banksUpdated obligations from 31 March 2026, as AUSTRAC and the OAIC both state
Tranche 2New designated services: real estate, conveyancing, legal, accounting, precious metals and stonesServices from 1 July 2026. Enrol by 29 July 2026
EitherA business that provides a designated service28 days after you start, if you start later

Where this page stops

This page is the difference. The year of the Act itself, which is neither 31 March nor 1 July, is when the AML/CTF Act was introduced.

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 a different price for Tranche 1 and Tranche 2. The client pays the check. Enrolment is done in AUSTRAC Online, not as a fee on this site.

Frequently Asked Questions

Work out which tranche your service is in, then do only that work.

The firm suite is A$0. The client pays KYC or KYB if you are the reporting entity.

Open the Tranche 2 guide

Questions: team@freeaml.com.au