AUSTRAC Tranche 2 for Real Estate Agencies: The 2026 Compliance Guide
From 1 July 2026, Australian real estate agencies step into a regulatory world that was, until now, largely the domain of banks and remitters. Under the "Tranche 2" reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), real estate professionals join lawyers, accountants and other high-risk gatekeeper professions as regulated reporting entities. That means enrolling with AUSTRAC, building an AML/CTF program, verifying who your buyers and sellers really are, and reporting certain transactions. This guide walks through what changes, who is captured, and the practical first steps for an agency principal or compliance lead.
The short version
- From 1 July 2026, real estate agents and property managers providing certain "designated services" are captured under the AML/CTF Act as part of the Tranche 2 reforms.
- You will need to enrol with AUSTRAC, maintain an AML/CTF program, and carry out customer due diligence (CDD) on the parties to relevant transactions.
- You must lodge a Threshold Transaction Report (TTR) for cash of AUD 10,000 or more (within 10 business days) and a Suspicious Matter Report (SMR) when you form a relevant suspicion.
- AUSTRAC is releasing new TTR and SMR forms on 1 July 2026 with expanded reportable details.
- Strong KYC, KYB and AML screening are the foundation that makes accurate reporting possible.
A note on sources. This information is current as of July 2026 and draws on AUSTRAC's published guidance, including its page on changes to transaction reporting from 1 July 2026 and its AML/CTF reform materials. Rules evolve — if you spot something that needs updating, please flag it via didit.me/contact.
What is Tranche 2, and why does it affect real estate?
For years, Australia's AML/CTF regime covered financial institutions, remittance providers and gambling operators. Tranche 2 closes a long-standing gap by extending the regime to Designated Non-Financial Businesses and Professions (DNFBPs) — the "gatekeeper" professions that criminals can use to launder money or disguise its origin. Property is a well-documented channel for moving and cleaning large sums, which is exactly why real estate is now in scope.
From 1 July 2026, the following sectors are brought into the regime for specified designated services:
| Sector | Examples of designated services |
|---|---|
| Real estate professionals | Brokering the sale, purchase or transfer of real estate |
| Lawyers & conveyancers | Acting in real-estate transactions, asset transfers |
| Accountants | Managing client money, forming entities |
| Dealers in precious metals & stones | High-value cash dealing |
| Trust & company service providers (TCSPs) | Forming and managing companies and trusts |
The common thread is that these professions can facilitate the movement of value in ways that obscure the true owner or source of funds.
Which real estate services are actually captured?
Not every task an agency performs is a designated service. The obligations attach to specific activities connected with real-estate transactions — principally brokering the sale, purchase or transfer of real estate on behalf of a client. In practice this captures sales agents facilitating a property transaction between a buyer and seller.
Property management sits in a greyer area: routine tenancy management is generally lower-risk, but you should confirm the precise treatment of your services against AUSTRAC's guidance rather than assuming you fall outside the net. The reforms also reach transactions such as transferring assets and the forming or managing of companies and trusts — relevant where a corporate or trust structure sits behind a property deal.
Because the exact boundaries of "designated services" carry legal consequences, confirm your agency's specific activities directly with AUSTRAC or your adviser.
Enrolment: your first obligation
Every captured entity must enrol with AUSTRAC. Enrolment is how AUSTRAC knows you exist as a reporting entity and how you gain access to AUSTRAC Online to lodge reports.
The timing of enrolment also affects which reporting forms you use:
| Enrolment status | Which TTR/SMR forms apply |
|---|---|
| Enrolled on or before 30 March 2026 | May transition to the new forms any time between 1 July 2026 and 30 March 2029 |
| Enrolled after 30 March 2026 | Must use the new forms from 1 July 2026 |
Newly captured real estate agencies enrolling in the lead-up to the reforms should plan on the assumption that they may be using the new forms from day one. Build your processes around the expanded data set rather than the legacy fields.
Building your AML/CTF program
A cornerstone obligation is maintaining an AML/CTF program — your documented framework for identifying, mitigating and managing money-laundering and terrorism-financing risk. At a high level, a program is expected to cover:
- A risk assessment of your business, customers, the services you provide, delivery channels and geographies.
- Customer due diligence (CDD) procedures — how you identify and verify customers, and when you apply enhanced measures.
- Ongoing monitoring of customers and transactions to detect unusual or suspicious activity.
- Reporting processes for TTRs, SMRs and other obligations.
- Governance — a nominated compliance officer, staff training, record-keeping and independent review.
Where Didit helps: A program is only as good as the identity data behind it. Didit provides KYC identity verification, KYB business verification, and sanctions/PEP screening through one API, so the "identify and verify the customer" and "screen for risk" steps of your CDD procedures run consistently and are captured with an audit trail — the evidence that underpins accurate reporting.
Customer due diligence on buyers and sellers
CDD is where most agencies will feel the day-to-day impact. Before (or as) you provide a designated service, you generally need to identify your customer and verify their identity using reliable, independent data. For a property transaction, that can mean verifying the parties on both sides of the deal, understanding who ultimately owns or controls a corporate or trust buyer, and assessing the risk each customer presents.
Key CDD building blocks include:
- Identity verification (KYC): confirm the individual is who they claim to be, using government-issued ID and, where appropriate, biometric checks.
- Beneficial ownership (KYB): where a company or trust is buying or selling, establish the natural persons who own or control it.
- Sanctions and PEP screening: check parties against sanctions lists and politically exposed person (PEP) data.
- Risk-based enhanced due diligence: apply deeper checks for higher-risk customers, unusual structures or high-value cash elements.
Where Didit helps: Didit runs document-based identity verification with biometric face matching and liveness, business (KYB) checks to unwind ownership structures, and sanctions/PEP screening — helping you collect and verify the identity data your CDD obligations require, and detect the parties that warrant a closer look.
When do TTRs and SMRs apply?
Two report types matter most for real estate agencies.
| Report | Trigger | Deadline |
|---|---|---|
| Threshold Transaction Report (TTR) | A cash transaction of AUD 10,000 or more (or foreign-currency equivalent) | Within 10 business days |
| Suspicious Matter Report (SMR) | You form a suspicion on reasonable grounds (e.g. money laundering, structuring, false identity) | Within 3 business days — or 24 hours if it relates to terrorism financing |
A TTR is triggered by the value and form of the transaction — physical currency at or above the threshold. An SMR is triggered by suspicion: something about the customer, the funds or the transaction doesn't add up. The two are independent — a transaction can require an SMR even if no cash threshold is crossed, and structuring (deliberately breaking cash into sub-threshold amounts) is itself a red flag.
Remember that AUSTRAC is releasing new TTR and SMR forms on 1 July 2026. The new AML/CTF Rules expand the reportable details required in both reports, with the aim of improving data quality and streamlining the AUSTRAC Online experience. For exact new field lists, work directly from the forms and guidance on austrac.gov.au.
Where Didit helps: Didit's transaction monitoring can surface unusual patterns — including potential structuring — and its verified identity records give you the accurate customer details the expanded TTR and SMR forms ask for. Didit does not lodge reports on your behalf; it helps you collect, verify and detect the information that makes your reports accurate and defensible.
Your first steps as a captured agency
If your agency is newly in scope, a sensible sequence is:
- Confirm your status. Map which of your services are designated services under the reforms, and check the detail with AUSTRAC or your adviser.
- Enrol with AUSTRAC and set up AUSTRAC Online access.
- Appoint a compliance officer to own the program and reporting.
- Write your risk assessment and AML/CTF program, tailored to property transactions.
- Stand up CDD workflows — identity verification, beneficial-ownership checks and sanctions/PEP screening for buyers and sellers.
- Set reporting procedures for TTRs and SMRs, and train staff to recognise red flags.
- Prepare for the new forms and their expanded data fields from 1 July 2026.
Starting early matters. Building identity verification and screening into your customer-onboarding flow now means that when the obligations bite, the underlying data is already clean, consistent and auditable.
Bring it all together with Didit
Meeting your Tranche 2 obligations starts with knowing exactly who you're dealing with. Didit gives real estate agencies one API for KYC identity verification, KYB business verification, sanctions and PEP screening, and transaction monitoring — with public per-check pricing and 500 free verifications per month to get started. Didit doesn't lodge your TTRs or SMRs, but it helps you collect and verify the identity data and detect the activity that makes those reports accurate.
This article is general information only and is not legal advice. AML/CTF obligations depend on your specific circumstances — confirm how the reforms apply to your agency with AUSTRAC or a qualified adviser.
