Open your ASIC agent list. Filter for the companies whose registered office is your own street address. Count them.
I have run that count with a few practices around Sydney this year and the number is almost never small. A 3-partner suburban firm I sat with in May had 147. The principal had never once thought of any of them as a service he was providing. The address was a box on a form, ticked at incorporation, untouched for a decade after that.
Every one of those 147 companies is a customer receiving a designated service under item 9 of table 6.
I think item 9 is the most under-noticed line in the whole professional services table. The drafting is not the problem. It runs to a single sentence and says exactly what it means. It gets missed because it does not feel like anything: no invoice, no file note, no phone call, nothing in the practice management system. It just sits in the ASIC record and accrues.
What item 9 actually says
Item | Provision of a designated service | Customer of the designated service |
9 | providing a registered office address or principal place of business address of a body corporate or legal arrangement, in the course of carrying on a business | the person to whom the service is provided |
The statutory home is table 6 of subsection 6(5B) of the AML/CTF Act 2006.
AUSTRAC is direct about the mischief. Item 9 regulates people who supply an address that the customer then notifies to ASIC in the absence of a true office address of their own, whether the reason is privacy, commercial preference, or the plain fact that the company has no physical presence in Australia. Equivalent addresses provided outside Australia are caught as well.
Free does not get you out
This is the point I end up arguing about most.
Almost nobody bills for the address. It disappears into the annual company review fee, or it goes out for nothing at all, and practitioners read that as proof it cannot be a service. AUSTRAC shut that door inside the guidance itself: it makes no difference whether the address is provided free of charge. The wider table 6 test says the same thing in broader language. A service is provided in the course of carrying on a business where the business provides it for a fee, or for free to otherwise further that business, and AUSTRAC adds that receiving something for free does not make the money laundering risk any lower.
Look at it from the other side of the desk. If what you wanted was a corporate shell with an address that reads like a professional office and leaves no payment trail, the free favour is the ideal product. Cheap to obtain, and invisible in anyone’s ledger. That is the risk the item is written at, which is why “we never charged for it” cuts the wrong way.
You already signed the evidence
Section 142 of the Corporations Act 2001 requires a company to have a registered office in Australia. Where the company is not the occupier of the premises, section 100 requires the occupier to have consented in writing to the address being used, and not to have withdrawn that consent. ASIC can require the company to produce that consent, and failing to produce it under section 143(1) is an offence of strict liability.
So there is a signed document, on your letterhead, sitting in your client file and producible to ASIC on demand, recording that you provide the address.
No factual argument is available to you here. Worth knowing that before anyone starts building a position.
What item 9 does not reach
The item names 2 addresses: the registered office address and the principal place of business address of a body corporate or legal arrangement. Both are addresses that go on the public record.
A plain postal or correspondence arrangement, where you receive a client’s ATO mail at your office and no address of yours is adopted as the company’s registered office or principal place of business, sits outside the words of item 9 as I read them. Watch that one. The reading changes the moment your address is notified to ASIC in either of those 2 capacities.
Services to a member of your own business group are outside as well. AUSTRAC regulates services provided to an external customer who is a separate legal person from the business, so the service trust or corporate trustee inside your own structure is not a customer, and neither is a related company that shares your premises in fact rather than on paper. A director’s personal address sits outside item 9 too, because the item attaches to the address of the entity. That distinction matters more than it sounds, since the same street address can appear in an ASIC extract in 3 or 4 different capacities and only some of them are the ones item 9 is talking about.
And if you are the one acting as director, secretary, attorney or trustee, that is item 7, not item 9. Holding shares for someone else is item 8. Different items, different customers, and worth separating on paper before you assume one file covers all of it.
The consequence that costs more than item 9 itself
Item 3 catches receiving, holding, controlling or managing a client’s money or property as part of assisting them in a transaction. It carries an exception in paragraph 6(5C)(b): where a business provides no designated services other than item 3, and the money handling is incidental to services that are not designated services, the item 3 exposure falls away.
Read the condition again. No designated services other than item 3.
AUSTRAC’s own worked example makes the link explicit. A bookkeeping practice holding client funds incidentally to its bookkeeping stays outside item 3 only while it does not also provide something like a business address service under item 9, or arrange for a person to fill a role under item 7. One free registered office for 1 client, and the incidental exception over the entire trust account is gone.
That is the version of this I want a principal to hear.
The address on its own is manageable. What it does to everything else in the analysis is the expensive part.
What follows once you are inside
Enrolment comes first. Section 51B(1) requires an application to enrol within 28 days of starting to provide a designated service, Tranche 2 enrolment opened on 31 March 2026, and a firm already providing a designated service on 1 July 2026 had until 29 July 2026. If you are reading this in August and the count at the top of this article came back above zero, that date has gone. Missing it does not extinguish the obligation. It keeps running until you enrol or until you stop being a reporting entity, so the useful move is to enrol now rather than to spend the time constructing a reason you did not. I have yet to see a version of that reason that survives being written down next to a signed occupier consent.
Then the program. Section 26B sets 2 components: an ML/TF risk assessment under sections 26C to 26E, and AML/CTF policies under section 26F. Anyone still drafting to a Part A and Part B structure is drafting to a model that has been repealed.
The companies already on your letterhead
This part is more workable than most people expect.
If you were in a business relationship with a client on 1 July 2026 and that relationship involved only table 6 designated services, the client is a pre-commencement customer. You can keep providing the address without completing initial customer due diligence, and no deadline attaches to it. The carve-out ends when either of 2 things happens: a suspicious matter reporting obligation arises for that customer, or the nature or purpose of the relationship changes significantly in a way that lifts their ML/TF risk to medium or high.
Pre-commencement does not mean untouched. Ongoing customer due diligence applies to those clients from the start: monitoring for unusual activity, keeping KYC information current, reviewing and reverifying at a frequency matched to risk.
A company that moves its registered office to your address after 1 July 2026 is a different animal. New customer, new designated service, and initial CDD belongs in front of the service rather than behind it. In practice the trigger is the Form 484 sitting in your outbox, which means the identification work has to be finished before you lodge, not in the week after.
What I would do this week
- Export the agent list, filter on your own address, and split the result at 1 July 2026. Everything before that date is a pre-commencement question. Everything after it is an initial CDD question.
- Check whether the address service is described anywhere in your engagement terms. In most of the firms I have looked at it is not, which makes it awkward to argue you understood what you were providing.
- Work out whether item 9 has quietly cost you the paragraph 6(5C)(b) exception over your trust account. That single question is worth more than the address review itself.
- Decide whether you still hand the address out for free. That is a commercial decision now, and it belongs with the partners rather than with whoever processes the ASIC forms.
If the split is going to run past a handful of companies, do it against real customer files rather than a spreadsheet column. That is the job HP-KYC was built for.
The free version was cheap while it was a favour. It stops being cheap once each one carries a customer file behind it.
Frequently asked questions
Does providing a registered office address trigger AML/CTF obligations?
Yes. Providing a registered office address or principal place of business address of a body corporate or legal arrangement, in the course of carrying on a business, is a designated service under item 9 of table 6 of the AML/CTF Act 2006. Providing it makes you a reporting entity with enrolment, program, customer due diligence, record keeping and reporting obligations from 1 July 2026.
Does it still count if I do not charge for it?
Yes. AUSTRAC states in its professional services guidance that it makes no difference whether the address service is provided free of charge. The general table 6 test treats a service as provided in the course of carrying on a business when it is supplied for a fee, or for free to otherwise further that business.
Is a mailing address the same as a registered office address?
No. Item 9 names the registered office address and the principal place of business address, both of which go on the public record. Receiving a client’s correspondence at your office, without your address being adopted as either of those, falls outside the wording. The position changes as soon as your address is notified to ASIC in one of those capacities.
Do I need to run CDD on the companies already using my address?
Usually not initial CDD. A client you were in a business relationship with on 1 July 2026, where the relationship involved only table 6 designated services, is a pre-commencement customer, and initial CDD is not required until a suspicious matter reporting obligation arises or the relationship changes significantly enough to lift ML/TF risk to medium or high. Ongoing CDD still applies to them from the start.
Is providing a registered office to my own group company a designated service?
No. AUSTRAC regulates services provided to an external customer who is a separate legal person from your business, and a service provided to a member of your own business group is not a designated service. A service trust or corporate trustee inside your own structure using your address is not a customer for item 9.
When did accountants have to enrol with AUSTRAC for this?
A firm providing a designated service on 1 July 2026 had to apply to enrol by 29 July 2026, being 28 days from the start of the service under section 51B(1). Enrolment opened on 31 March 2026. Missing the date does not remove the obligation, which continues until you enrol or stop providing designated services.
The technical detail
- Designated service: item 9, table 6, subsection 6(5B), Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). “providing a registered office address or principal place of business address of a body corporate or legal arrangement, in the course of carrying on a business”. Customer: the person to whom the service is provided.
- Adjacent items: item 5 (selling or transferring a shelf company); item 7 (acting as, or arranging for another person to act as, director or secretary of a company, power of attorney of a body corporate or legal arrangement, partner in a partnership, or trustee of an express trust, with an exception at subsection 6(5E)); item 8 (nominee shareholder). Customer for items 7 and 8 is the nominator.
- Item 3 incidental exception: paragraph 6(5C)(b). Available only where the business provides no designated services other than item 3.
- Group services: not a designated service where provided to a member of the same business group, the customer being an external person separate from the business.
- Corporations Act 2001 (Cth): section 142 (registered office required); section 100 (written consent of the occupier where the company is not the occupier, and consent not withdrawn); section 143(1) (ASIC may require production of the consent, strict liability).
- Commencement: table 6 obligations apply from 1 July 2026. Enrolment opened 31 March 2026. Application to enrol due within 28 days of commencing to provide a designated service, section 51B(1), which is 29 July 2026 for a service being provided on 1 July 2026.
- AML/CTF compliance officer notification: 29 July 2026 for newly regulated entities, 30 May 2026 for entities already reporting before the reforms.
- AML/CTF program: section 26B, comprising an ML/TF risk assessment (sections 26C to 26E) and AML/CTF policies (section 26F). The former Part A and Part B structure is repealed.
- Pre-commencement customers: sections 28, 30 and 36. Business relationship on 1 July 2026 involving only table 6 designated services. Initial CDD triggered by an SMR obligation or by a significant change in the nature or purpose of the business relationship that raises ML/TF risk to medium or high.
- Independent evaluation of the AML/CTF program: frequency set by the reporting entity, with a statutory floor of at least once every 3 years.
- Commonwealth penalty unit: $364 from 1 July 2026, previously $330. Failure to apply to enrol contravenes section 51B, a civil penalty provision, with the amount fixed by the court.
