Am I Even Captured? How Australian Accountants Determine AML/CTF Reporting Entity Status in 2026

The single most important question for any Australian accounting practice ahead of 1 July 2026 isn't how to comply with the AML/CTF reforms — it's whether you have to at all. Because here's the part that surprises most firms: being an accountant does not automatically make you an AUSTRAC reporting entity.

Under the Tranche 2 reforms, your obligations turn on the designated services you provide, not on your professional label. A practice that only prepares tax returns may not be captured at all. A practice that sets up a single trust for a client almost certainly is. This article walks through how to make that determination — and document it.

The threshold concept: designated services

The AML/CTF regime regulates a defined list of designated services, set out in section 6 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. The services relevant to accountants, lawyers and trust and company service providers sit in what's known as Table 6.

You become a reporting entity if you provide one or more of those designated services in the course of carrying on a business, with a geographical link to Australia. Provide none of them, and the regime doesn't apply to you — no enrolment, no program, no reporting.

Which accounting services are designated services?

Broadly, an accounting practice is likely to be in scope where it provides services such as:

• Receiving, holding, controlling or managing a client's money or assets as part of facilitating a transaction (for example, money passing through the firm to be disbursed to third parties).
• Creating, or restructuring, a company or a trust for a client.
• Acting as — or arranging for someone to act as — a nominee director, secretary, trustee or partner.
• Acting as, or arranging, a nominee shareholder.
• Providing a registered office or principal place of business address for an entity.
• Assisting a client to buy, sell or transfer a body corporate or legal arrangement (a company, trust or business), or to buy, sell or transfer real estate.
• Assisting with equity or debt financing transactions.

In practice, firms that administer SMSFs involving structural changes, set up companies or trusts, act as nominees, or run a trust account through which client funds flow are the ones most likely to be captured.

What is generally not a designated service

This is where the "you might not be captured" point becomes real. On AUSTRAC's guidance, the following generally do not, by themselves, make you a reporting entity:

• Preparing tax returns and providing tax advice that doesn't directly advance a specific transaction.
• BAS preparation and general bookkeeping.
• Audit and assurance work.
• Pure advisory work — for example, advising on the tax implications of a possible sale before any transaction is on foot. The designated service typically begins only when you act on instructions in relation to a real, identified transaction.

There's also an important carve-out for handling client money for routine, ancillary payments. Disbursing funds for things like tax payments to the ATO, ASIC filing fees, court filing fees, insurance payments and routine payroll, super or creditor payments under a client's authority generally won't, on their own, pull a bookkeeping or BAS practice into the regime.

How to make — and record — the determination

1. List every service line your practice actually delivers, including occasional and low-volume ones, and work done by non-accounting staff.
2. Map each service against the Table 6 designated services and the AUSTRAC guidance on what counts as "assisting" a transaction.
3. Use AUSTRAC's free online self-assessment tool as a cross-check.
4. Where a service sits on the line, get advice. Edge cases — particularly around when "assisting" begins and whether an exemption applies — are exactly where professional advice earns its keep.
5. Document your conclusion and your reasoning. If you determine you're out of scope, a written record of why is your protection if the question is ever revisited.

If you are in scope for even one service line, you must enrol with AUSTRAC (enrolment opened 31 March 2026; the deadline is 29 July 2026, and new entrants must enrol within 28 days of first providing a designated service) and build an AML/CTF program before you provide that service.

How Veriqua helps

Veriqua's Designated Service Assessment module is designed to walk your practice through each service you provide, map it against the statutory definitions, and produce a dated, documented record of your determination — including the services you concluded were out of scope and why. If your position is ever questioned, you have the reasoning on file rather than a vague recollection.

Veriqua supports your assessment; it doesn't replace professional advice on genuine edge cases or your responsibility as a reporting entity.