AML Tranche 2 for Accountants and Tax Agents: Which of Your Services Actually Make You a Reporting Entity

The short answer: Not every accounting or tax practice is caught by the Tranche 2 AML/CTF reforms that commenced on 1 July 2026, and being an accountant or tax agent does not, on its own, make you a reporting entity. What matters is whether you provide a "designated service."

As this breakdown of the professional-services rules explains, AUSTRAC’s framing is that "it is what you do, not what you are, which is important." Broadly, pure advisory and compliance work, such as preparing tax returns, lodging BAS and giving general business advice, is generally not caught.

But if you manage client money, set up or restructure companies and trusts, act as a nominee director or trustee, or help clients buy and sell businesses, you are almost certainly a reporting entity and now have obligations to meet. That distinction is doing all the work, and it is the thing most practices are getting wrong in both directions. Here is how to work out where you actually stand.

Isn’t Tranche 2 a “Lawyers and Real Estate” Problem?

No. That is the most common misread, and it is why many accounting and tax practices have been slow to check their own position. As the Home Affairs overview of the Amendment Act sets out, Tranche 2 brings six broad professional groups into the AML/CTF regime: lawyers, conveyancers, real estate agents, property developers, dealers in precious metals and stones, and accountants and tax agents.

The reason accountants keep getting left out of the conversation is that the reform doesn’t regulate professions. It regulates services. A practice that looks identical to the one down the road can have completely different obligations, depending on what work it actually does.

What Decides Whether I’m Captured?

A single test: do you provide a "designated service" listed in the professional-services table of the AML/CTF Act (the industry shorthand is "Table 6")? If you do, you are a reporting entity for that service. If you don’t, you are not.

The organising principle, as the same professional-services guide summarises it, is AUSTRAC’s line that "it is what you do, not what you are." A tax agent who only ever prepares and lodges returns may sit entirely outside the regime. An accountant in the next office who forms companies and holds client funds is squarely inside it. Same qualification, different obligations.

The cleanest way to think about it is this: advising is generally not a designated service, but acting to execute a transaction generally is. Guidance on the professional-services items makes the point that pure advisory work "without acting on instructions to execute a transaction" may not amount to a designated service at all. The moment you move from telling a client what they could do to actually doing it for them, moving the money, forming the entity or transferring the asset, you are more likely to be captured.

Which of My Services Are Caught, and Which Aren’t?

Here is the practical split for accounting and tax practices. Treat it as a starting map, not a ruling on your specific facts.

Two things to notice. First, the "not caught" column is where a lot of everyday accounting and tax work lives, which is genuinely reassuring for practices whose services stay in that lane. Tax agents who simply prepare and lodge returns are unlikely to be in scope at all.

Second, the line can run straight through a single client relationship. You might prepare a client’s tax return (not caught) and, in the same year, set up a family trust for them (caught). The obligations attach to the designated service, not to the client or the engagement as a whole.

I Mostly Do Returns and BAS, Am I Safe?

If your practice genuinely stays within tax-return preparation, BAS lodgement and general advice, you are unlikely to be a reporting entity. The reforms were not designed to sweep in routine compliance work, and the "not caught" list above reflects that.

The catch is how many practices quietly drift across the line without thinking of it as a separate service. Setting up a company or trust for a small-business client. Holding client funds in the course of a matter. Providing a registered office address as a convenience. Stepping in as a nominee director or trustee because the client asked. Each of those is a designated service in its own right, and one is enough to make you a reporting entity for that work.

This matters most for practices serving cash-intensive small businesses, where structuring, fund-handling and registered-office arrangements are common. It is worth being honest with yourself about which of those services you actually provide, rather than assuming your practice type answers the question for you.

If I Am Captured, What Do I Actually Have to Do?

None of this requires you to become an AML specialist overnight. It does require a documented, repeatable process for the designated services you provide.

Should I Be Worried About Getting It Perfect From Day One?

No, and the regulator has been unusually clear about that. In its guidance on the reforms, AUSTRAC CEO Brendan Thomas has said the regulator is "not expecting perfection on day one," while it does expect firms to take "reasonable steps." On smaller practices specifically, he has said AUSTRAC has "never penalised a small business for administrative mistakes, and we have no intention of starting now," with enforcement aimed at those who "wilfully ignore" their obligations.

Read that the right way. It is not a licence to do nothing. A practice that provides a designated service and never checks its position is exactly the kind of "wilful" gap the regulator has flagged. But it does mean a genuine, well-documented effort to get set up is the expectation, not flawless compliance from the first hour of 1 July.

What to Do Now

If you take one thing from this, take this: the question "am I captured?" is answered service by service, not by your job title. Work through your list honestly and you will know exactly where you stand.

Getting the Factual Layer off Your Plate

For captured engagements, the heaviest part of all this is the repetitive factual layer: verifying identity, confirming beneficial ownership, screening against sanctions, PEP and adverse-media lists, and keeping a seven-year audit trail you can produce on request. It is essential, it is mandatory, and it is the part most likely to eat into billable time.

That is the part VeriEzi is built to carry: AUSTRAC-aligned identity verification and customer due diligence, PEP, sanctions and adverse-media screening, and a complete, exportable seven-year audit trail, so the compliance admin behind your designated services doesn’t swallow the advice work only you can do. See how it works.