Tranche 2 Timeline: Every Key Date You Need to Know (2026-2029)

Australia's Tranche 2 AML/CTF reforms represent the largest expansion of anti-money laundering regulation since the original Act was introduced in 2006. For real estate agents, accountants, lawyers, and conveyancers, the next three years are packed with milestones and deadlines. This article sets out every key date you need to know.

Background

The AML/CTF Amendment Act extending regulation to designated non-financial businesses and professions (DNFBPs) was passed by the Australian Parliament in 2025. The reforms bring Australia into compliance with FATF recommendations that have been outstanding for nearly two decades.

AUSTRAC is the regulator responsible for overseeing Tranche 2 compliance. The rollout follows a phased approach, with different obligations kicking in at different stages.

The Complete Timeline

Q1 2026 — AUSTRAC Enrolment Opens

January to March 2026: AUSTRAC opens its enrolment portal for Tranche 2 reporting entities. All businesses providing designated services — including real estate agencies, accounting practices, law firms, and conveyancing practices — should register during this period.

Enrolment is free and completed online. You will need:

• Your ABN
• Details of your designated services
• The name of your AML/CTF compliance officer
• Contact information for your business

Action: Do not wait until the last minute. Register as soon as the portal opens to avoid bottlenecks closer to the compliance deadline.

Q2 2026 — Program Development Period

April to June 2026: This is your preparation window. By the end of this period, you should have:

• Completed your ML/TF risk assessment covering customer types, services, delivery channels, and geographic exposure
• Developed your AML/CTF program (Part A — systems and controls, Part B — customer identification procedures)
• Established your CDD procedures for onboarding new clients
• Set up your record-keeping systems for retaining compliance documentation
• Arranged staff training so that all relevant employees understand their obligations

AUSTRAC has indicated it will publish sector-specific guidance during this period to help Tranche 2 businesses understand what is expected.

1 July 2026 — Compliance Date

This is the hard deadline. From 1 July 2026:

• You must have a compliant AML/CTF program in place
• CDD must be conducted on all new clients before providing designated services
• You must be capable of identifying and reporting suspicious matters to AUSTRAC
• Staff must have received initial AML/CTF training
• Records must be kept in accordance with the seven-year retention requirement

There is no grace period for the core obligations. Businesses that are not compliant by this date are exposed to regulatory action.

H2 2026 — AUSTRAC Compliance Assessments Begin

July to December 2026: AUSTRAC has signalled that it will begin conducting compliance assessments of Tranche 2 entities in the second half of 2026. Initial assessments are expected to focus on:

• Whether the business has enrolled with AUSTRAC
• Whether an AML/CTF program exists and is documented
• Whether CDD procedures are being applied to new clients

AUSTRAC has historically taken an education-first approach with newly regulated sectors, but this should not be mistaken for leniency. Businesses that have made no effort to comply will face enforcement action.

2027 — First Annual Reviews Due

By 30 June 2027: Businesses that became reporting entities on 1 July 2026 must complete their first annual review of their AML/CTF program. The review must be conducted by someone with sufficient independence and must produce a written report.

This is also when AUSTRAC is expected to ramp up its compliance activities, moving beyond initial assessments to more detailed reviews of program effectiveness, CDD quality, and reporting practices.

2027-2028 — Transition Period for Existing Clients

July 2026 to June 2028: AUSTRAC has allowed a two-year transition period for conducting retrospective CDD on existing clients. This means:

• New clients from 1 July 2026 must be identified before you provide services
• Existing clients (those with whom you had a relationship before 1 July 2026) must have their identity verified by 30 June 2028

Use this transition period strategically. Prioritise high-risk existing clients — those with complex structures, large transaction volumes, or connections to higher-risk jurisdictions — and work through your lower-risk client base over the full two years.

2028 — Full CDD Coverage Required

By 30 June 2028: All clients, both new and existing, must have completed CDD. There are no further extensions. Any client whose identity has not been verified by this date should not be provided with designated services until CDD is completed.

2029 — Mature Compliance Expected

By mid-2029: AUSTRAC will expect Tranche 2 reporting entities to be operating mature compliance programs. This means:

• Multiple annual reviews completed with documented improvements
• Ongoing CDD and transaction monitoring embedded in business processes
• Staff training current and regularly refreshed
• SMR reporting fully operational
• Record-keeping systems established and accessible

Enforcement activity is expected to increase for businesses that continue to show gaps in their compliance programs.

Key Dates Summary

| Date | Milestone | |------|-----------| | Q1 2026 | AUSTRAC enrolment portal opens | | Q2 2026 | Program development and preparation period | | 1 July 2026 | Compliance date — all core obligations commence | | H2 2026 | AUSTRAC begins compliance assessments | | 30 June 2027 | First annual program review due | | 30 June 2028 | Retrospective CDD on existing clients must be complete | | Mid-2029 | Mature compliance expected; increased enforcement |

Do Not Leave It to the Last Minute

The businesses that will navigate Tranche 2 most smoothly are those that start preparing now. Waiting until June 2026 to begin building your AML/CTF program creates unnecessary risk and stress.

ComplyReady helps you hit every deadline with confidence. Our platform walks you through enrolment preparation, generates your AML/CTF program, and manages your CDD and training obligations with built-in reminders and audit-ready documentation.

Get started today and stay ahead of every milestone.