Key dates for Tranche 2 compliance: Timeline and deadlines
Understanding the critical dates and milestones for AML/CTF Tranche 2 implementation is essential for timely compliance. Here's your comprehensive timeline.
Critical Alert
Tranche 2 entities come under AUSTRAC regulation from 1 July 2026. Enrolment opens 31 March 2026 and cannot be done earlier. Ensure your AML/CTF program is in place before providing any designated services. Non-compliance may result in significant penalties.
Complete Timeline
AUSTRAC Enrolment Portal Opens
The AUSTRAC online enrolment system becomes available for reporting entities to register. Note: enrolment cannot be done earlier than this date.
- Business ABN and ACN (if applicable)
- Details of compliance officer
- Business contact information
- List of designated services you'll provide
Tranche 2 Obligations Apply
All AML/CTF Tranche 2 obligations apply from this date. Businesses providing designated services must be enrolled with AUSTRAC and comply with all requirements including customer due diligence, record keeping and reporting obligations.
- AUSTRAC enrolment finalised
- AML/CTF program written and adopted
- Compliance officer appointed
- Staff training completed
- Customer due diligence procedures implemented
- Record keeping systems in place
First Independent Evaluation Due
Under Rule 5-10, reporting entities must have their AML/CTF program independently evaluated at intervals not exceeding 3 years. The first evaluation is due by 30 June 2029 (3 years from commencement). An earlier review may be required if there is an adverse finding, AUSTRAC issues a direction, or there is a material change in your circumstances.
- Must be conducted by someone independent of day-to-day operations
- Should assess compliance with all program requirements
- Must result in a written report
- Board or senior management should review findings
Preparation Timeline
To ensure smooth compliance, many professionals follow a preparation schedule similar to this:
- Understand which services are in scope
- Conduct preliminary risk assessment
- Review current client identification processes
- Budget for compliance costs
- Identify or recruit compliance officer
- Draft your AML/CTF program documentation
- Develop customer due diligence procedures
- Create suspicious matter reporting workflows
- Establish record keeping systems
- Prepare staff training materials
- Finalise AML/CTF program documentation
- Have solicitor review and customise documents
- Board/partners approve program
- Complete AUSTRAC enrolment
- Conduct staff training
- Test procedures with sample clients
- Refine processes based on feedback
- Ensure all systems are operational
- Complete any additional training
- Final compliance readiness check
- All compliance obligations apply from this date
- Apply procedures to all new engagements
- Monitor compliance effectiveness
- Document any issues for resolution
Don't leave it too late
Many businesses underestimate the time required to develop, implement and test an effective AML/CTF program. Common pitfalls include:
- Underestimating documentation time: Developing and customising an AML/CTF program requires significant time and complexity varies widely by firm
- Delayed legal review: Solicitors' availability in March-April 2026 may be limited as demand peaks
- Insufficient staff training: Ensuring all team members understand their obligations takes time
- Technology challenges: Setting up verification and record keeping systems may require IT support
- Process testing: You need time to test procedures before they're required
Read our complete Tranche 2 Guide
Key dates, affected sectors, obligations and how to prepare
Get ahead of the deadline
HeadStart Docs provides free AML/CTF program documents as a starting point, giving you time to prepare and work with your lawyer to customise for your business.
Disclaimer: This article is general information only. It is not legal, financial or compliance advice. HeadStart Docs™ provides free compliance documents, not legal services.
We do not guarantee the accuracy of information provided. Obligations may apply depending on your designated services. Always confirm your specific requirements with a qualified adviser.
Need a lawyer to review your AML/CTF program? HeadStart Counsel offers fixed-fee tailoring from $1,800+GST. Separate entity and engagement.