For Bookkeepers

AML/CTF program for bookkeepers & BAS agents — AUSTRAC Tranche 2

If you receive, hold or disburse client money — paying suppliers, running payroll from client funds, or managing client accounts — you may become a reporting entity on 1 July 2026. AutoAML drafts the required documents from the services you actually provide.

Start Free View Requirements

Compliance Challenges for Bookkeepers

From 1 July 2026 bookkeepers and BAS agents who provide a designated service — like managing client money or accounts — fall under the AML/CTF Act. Generate your AUSTRAC-ready program in under 10 minutes.

It's the service, not the 'bookkeeper' label, that triggers obligations

AUSTRAC captures specific 'designated services' — managing client money or accounts, and paying third parties on a client's behalf among them. Plenty of bookkeepers and BAS agents do at least one without realising it brings them under the Act.

Holding and moving client money is a channel AUSTRAC watches

Receiving client funds and paying them onward — to suppliers, payroll or the ATO — is exactly the flow the regime monitors. Cash or cash-equivalent amounts of $10,000+ trigger a Threshold Transaction Report under s 43 of the Act.

BAS-agent and TPB duties don't substitute for an AML/CTF program

Your TPB Code of Professional Conduct and BAS-agent obligations are a separate regime from AUSTRAC's. The AML/CTF program is its own documented compliance system that AUSTRAC can audit directly — having one doesn't satisfy the other.

Sole traders and small practices still need a proportionate program

The Act applies regardless of size if you provide a designated service. Your program can be scaled to your risk profile, but it still needs Part A and Part B, a named Compliance Officer (which can be you), and independent review.

What Bookkeepers Need for Compliance

The AML/CTF Act 2006 (Cth) and the AML/CTF Rules require all reporting entities to maintain these documents and procedures.

AML/CTF Program covering Part A (risk-based systems) and Part B (CDD) — s 81 of the Act

ML/TF Risk Assessment scoped to the designated services you actually provide

Customer Due Diligence procedures aligned with Chapter 4 of the AML/CTF Rules

Suspicious Matter Report (SMR) workflow — 3 business days, 24 hours for terrorism financing

Threshold Transaction Report (TTR) procedure for $10,000+ physical-currency equivalents

Record-keeping aligned with the 7-year retention requirement under s 107

AML/CTF Compliance Officer appointment and reporting line to senior management

Annual independent review and a documented staff training program

Deadline & Applicability

Tranche 2 of the AML/CTF reforms commences 1 July 2026. From that date, bookkeepers and BAS agents providing one or more designated services must be enrolled with AUSTRAC, have a program in place, and be operating it day-to-day. The AML/CTF Amendment Act 2024 confirmed the start date.

Last reviewed: 18 April 2026 · Information is general guidance, not legal advice.

How AutoAML Helps Bookkeepers

AI-Generated Documents

All 13 compliance documents drafted from your service mix and risk profile — Part A, Part B, risk assessment, CDD scripts, the lot.

Team & Audit Trail

Invite your team, assign Compliance Officer roles, and keep a tamper-evident audit log AUSTRAC supervisors can read.

SMR & TTR Built-in

Reporting workflows, training tracking, annual review reminders and document version control — so the program stays alive after day one.

Frequently Asked Questions

Bookkeepers & AUSTRAC: common questions

Are all bookkeepers caught by AUSTRAC from July 2026?

No — only bookkeepers and BAS agents providing one or more 'designated services' under the amended AML/CTF Act. The common triggers are managing client money or accounts and paying third parties on a client's behalf. Pure data-entry bookkeeping with no handling of client funds is generally outside scope, so it comes down to your actual service mix.

I just run payroll and pay supplier invoices for clients — am I in scope?

Quite possibly. Receiving and disbursing client money can be a designated service. If you hold or move client funds, the safe course is to assess your obligations rather than assume you're exempt — the trigger is the service you provide, not your job title.

I'm a sole trader / BAS agent. Do I still need a full AML/CTF program?

Yes, if you provide a designated service. The Act applies regardless of firm size. Your program can be proportionate to your risk profile, but it still needs to cover Part A and Part B, name a Compliance Officer (which can be you), and be subject to independent review.

How does this interact with my TPB and BAS-agent obligations?

They're complementary, not substitutes. The TPB Code and your BAS-agent duties impose their own requirements, but the AML/CTF program is a separate, documented compliance system that AUSTRAC supervises directly.

How long does it take, and what does it cost?

Manually with consultants, typically 6–12 weeks and $5,000–$25,000 in fees. With AutoAML, a draft of the required documents tailored to your service mix is generated in under 10 minutes; expect to spend a few hours reviewing and adopting them. You remain responsible for reviewing and operating your program.

Do I need to enrol with AUSTRAC before 1 July 2026?

Yes. Enrolment is the first step and is separate from registration (which only certain businesses need). AUSTRAC has indicated guidance and an enrolment portal will be available before the commencement date.

Related industries under AUSTRAC Tranche 2

Many firms work across more than one designated-service category. Check the related sectors below.

For Accountants

Stand up your AUSTRAC program for bookkeepers in 10 minutes

All 13 AUSTRAC-aligned documents drafted from your service mix. Free until the 1 July 2026 deadline.

Start Your Free Compliance Program Prefer to talk first? Book a 15-min setup call

Free until the 1 July 2026 AUSTRAC deadline. Cancel anytime.