From 1 July 2026, accountants join Australia’s AML/CTF regime. The reaction we hear most is some version of: so is my whole practice caught now? For most firms the answer is no, and it pays to know exactly why.
The regime works on services, not job titles. AUSTRAC’s own line is the one to hold onto: it is what you do, not what you are. Being an accountant does not put you in. Providing one of a specific list of services does.
That list is Table 6 of the Act, and it has 9 items. This article walks through them the way a practice actually meets them: the ones you are likely to hit, the ones you almost never will, and the few services that look caught but are not, and the reverse.
The services you are likely to hit
Most practices that get caught get caught on the same handful of items, and they cluster around company and trust work.
Setting up or restructuring a company or a trust is item 6. This is the big one, because structuring is everyday work. A new trading company, a discretionary trust for a property purchase, a restructure to bring in a partner: all designated services.
Acting as a trustee, director or secretary, or arranging someone to, is item 7. Plenty of firms sit on a corporate trustee or take a directorship for a client. That is in.
Putting your firm’s address down as a registered office is item 9. A small thing you might do as a convenience, and it counts.
Holding a client’s money to move a transaction along is item 3. This is the one we get asked about most, and it carries the most nuance, so it gets its own section below.
Helping a client buy or sell a business is item 2, and arranging the finance behind a company or trust deal is item 4. Selling a ready made shelf company is item 5. These show up less in a tax practice and more in advisory and corporate work, but when they show up, they are in.
Accounting service | Triggers? | Which item, or why not |
Setting up a company | Yes | Item 6, creating a body corporate or legal arrangement |
Setting up a trust | Yes | Item 6, creating a legal arrangement |
Restructuring a company or trust | Yes | Item 6, restructuring |
Acting as trustee, director or secretary | Yes | Item 7, or arranging someone to act |
Providing a registered office address | Yes | Item 9, registered office or principal place of business |
Holding funds to settle a purchase | Yes | Item 3, money held to advance a transaction |
Assisting a business sale or purchase | Yes | Item 2, transferring a body corporate or legal arrangement |
Arranging finance for a company or trust | Yes | Item 4, equity or debt financing |
Selling a shelf company | Yes | Item 5 |
Preparing and lodging tax returns | No | Not a designated service |
BAS and GST work | No | Not a designated service |
Bookkeeping and payroll | No | Not a designated service |
Audit and assurance | No | Not a designated service |
General tax advice | No | Not a designated service on its own |
Paying a client’s ATO or ASIC fees | No | Carved out as a routine ancillary payment, s 6(5C) |
The services that do not trigger it
This is the part most firms are relieved to read, and it covers the bulk of what a tax and accounting practice does day to day.
Preparing and lodging tax returns. BAS and GST. Bookkeeping. Payroll. Audit and assurance. General tax advice. SMSF annual compliance. None of these, on its own, is a designated service. You can build an entire practice on this work and never touch Table 6.
The catch is in the words on its own. A firm that does returns and also sets up the occasional trust is caught for the trust work, not the returns. The regime attaches to the service, so one practice can have a little work inside the net and most of it outside.
The one that needs care: holding client money
Item 3 covers receiving, holding, controlling or managing a client’s money or property to help a transaction happen. Read literally, that sounds like it swallows every trust account, which is why the carve-out matters.
Routine, ancillary payments are out. Paying a client’s ATO tax bill from funds you hold, settling ASIC fees, court filing fees, an insurance premium: that incidental movement is excluded by the Act. The line is whether you are moving money to advance a deal, or just handling ordinary payments for a client.
So a trust account used for everyday client payments does not put you in. A trust account used to hold and disburse the purchase price on a property or a business does.
Where the edges catch people
A few edges decide more borderline cases than the headline items do.
One-off and free still count. The reforms turn on the kind of activity, not how often you do it or whether you charge. The trust you set up at cost for a family member is the same designated service as one you bill at full rate.
Advice can be the service. AUSTRAC has been clear that advice complete enough for a client to act on, say, advice that lets someone create a trust without further help, can itself be a designated service under item 6. Stopping short of doing the thing does not always keep you out.
Two edges run the other way. In-house work is generally out: serving your own employer is not a separate reporting obligation. And backward-looking work tends to be safe, because Table 6 is about matters in progress or ahead of you. Advising on whether a deal that already closed was valid is not the same as helping a deal happen.
How to check your own practice
The practical test is short. Take each service you offer and run it past the 3 questions: does money move, does an entity get created or restructured, does ownership change hands. Then add the timing check: is the matter in progress or ahead, rather than history.
If a service clears all of that as a no, it is very likely outside Table 6. If any answer is yes, treat it as a designated service and plan for what follows: enrolment, a compliance officer, a program, customer due diligence before you act, and record-keeping that holds up.
Working out which services catch you is the first hour of the job. Proving you did the customer checks before you acted, every time, with the evidence locked to its source, is the part that runs for years. HP-KYC was built to carry that: document, officer check, then locked to source.
For the bigger picture of what the reforms ask of a small firm, start with what Tranche 2 means for your firm.
The legal detail
Legislative references and dates, current as at June 2026. General information, not advice for a specific practice.
- Designated services for professionals: Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) s 6, Table 6 (Professional services), inserted as subsection 6(5B) by Schedule 3, Part 3 of the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) (C2024A00110). Table 6 commences 1 July 2026.
- Table 6 items: (1) real estate transfers; (2) buying, selling or transferring a body corporate or legal arrangement; (3) receiving, holding, controlling or managing a person’s money or property to assist a transaction; (4) equity or debt financing for a body corporate or legal arrangement; (5) selling a shelf company; (6) creating or restructuring a body corporate or legal arrangement; (7) acting as, or arranging for a person to act as, a director, secretary, trustee, partner or similar fiduciary role; (8) acting as, or arranging for a person to act as, a nominee shareholder; (9) providing a registered office or principal place of business address.
- Incidental client-money exclusions: s 6(5C) to (5E). The AML/CTF Rules carve item 3 out for routine ancillary payments, including tax payments to the ATO, ASIC filing fees, court filing fees, insurance payments, and bail paid through a trust account.
- Advice as a designated service: AUSTRAC professional services reform guidance (October 2025) treats advice that is comprehensive enough to let a client act without further professional assistance as capable of being a designated service, for example under item 6.
- Geographical link: s 6(6). An item applies only where the service is provided at or through a permanent establishment in Australia.
- Commencement and enrolment: enrolment opens 31 March 2026; obligations commence 1 July 2026; an entity providing a designated service on 1 July 2026 must enrol by 29 July 2026.
- Source framing: AUSTRAC: the regime regulates services, not professions, so it is what you do, not what you are.
