Your AML compliance timeline: what real estate agencies need to do before July 2026 — AML Simple

1 July 2026 is 71 days away. There is enough time to have your AML/CTF compliance foundations in place — but not enough time to leave it until June.

This is a week-by-week action plan for getting compliant before the deadline. It assumes you are starting from scratch. If you have already started, find your current step and continue from there.

Start today: three steps in under 30 minutes

You do not need to wait to start. Three steps give you your compliance foundations today:

Sign up to AML Simple — around 2 minutes. Enter your ABN and your organisation profile is pre-filled automatically.
AUSTRAC Enrolment Cheat Sheet — around 5 minutes. Open AUSTRAC Connect in one tab, open the Cheat Sheet in another. Every field pre-filled from your account. Copy-paste down the form and submit.
AML/CTF Program Generator — around 15 minutes. The wizard asks about your agency's services, team, and risk profile. Your program document — consistent with AUSTRAC's Program Starter Kit — is generated and ready for senior management sign-off.

After those three steps: you are enrolled, your program is built, and your record-keeping has started. The work that comes next is about training your staff, setting up your CDD process, and being ready to operate compliantly from 1 July.

Want the full week-by-week plan? Here it is.

The key dates

Date	What it means
31 March 2026	AUSTRAC enrolment opened — available now
1 July 2026	All obligations commence — CDD, screening, record-keeping
29 July 2026	Enrolment deadline for newly regulated entities
29 July 2026	Compliance Officer notification deadline
31 March 2027	First Annual Compliance Report due (covering 1 July–31 Dec 2026)

Source: AUSTRAC key dates for newly regulated entities

Week 1–2: Foundations (Do this now)

Step 1: Enrol with AUSTRAC

AUSTRAC enrolment is open now. Go to AUSTRAC Connect (austrac.gov.au) and complete your enrolment. You will need:

Your ABN and entity details
Your designated services (brokering real estate sales)
Your Compliance Officer's name and contact details
Your principal place of business address

Enrolment typically takes 20–30 minutes. Once done, you receive your AUSTRAC Account Number, which you will need for ongoing reporting.

Deadline: 29 July 2026. Do it now — there is no advantage in waiting.

Step 2: Build your AML/CTF program

Your program is the written document that explains how your agency manages AML/CTF risk. It must exist before you start providing designated services under the new rules.

AUSTRAC provides a free Program Starter Kit for agencies with 15 or fewer staff. It includes Word templates with the required structure.

The AML/CTF Program Generator in AML Simple takes around 15 minutes and produces a program consistent with the Starter Kit structure, customised to your agency.

Once generated, your program requires senior management review and sign-off before it becomes operational. Do this in Week 1 — and note the date of sign-off in the document.

Step 3: Name your Compliance Officer

Your AML/CTF program must name a Compliance Officer at senior management level. In most small agencies, this is the principal. You must notify AUSTRAC of the Compliance Officer's details by 29 July 2026.

If you used AML Simple for enrolment, your Compliance Officer's details are captured during the enrolment cheat sheet process.

Week 3–4: Complete your risk assessment

Your ML/TF risk assessment is the foundation of your program — it documents the money laundering and terrorism financing risks specific to your agency across four categories: customers, services, delivery channels, and geographic locations.

If you used the AML Simple Program Generator, the risk assessment is part of the generated program. Review it and adjust it for your agency's specific circumstances. Add any risk factors that are specific to your area, client mix, or service type.

The risk assessment must be reviewed and approved by senior management — separate from the program sign-off if done at different times, or as part of the same session.

For a detailed guide to completing your risk assessment, read How to complete your ML/TF risk assessment as a real estate agency.

Source: AML/CTF Act 2006, s 165; AUSTRAC risk assessment guidance

Week 4–5: Train your staff

Every staff member who will perform AML-relevant duties must be trained before they start those duties. For existing staff, this means before 1 July 2026.

AML-relevant duties include:

Collecting and verifying client identity information
Screening clients against the sanctions list
Assessing transaction risk
Escalating suspicious activity

Training must cover: the obligations, how to identify suspicious activity, escalation procedures, CDD requirements, record-keeping, and the consequences of non-compliance.

Training records must be retained for 7 years. Record who was trained, when, and what was covered.

AML Simple includes in-platform staff training. Staff can complete training in the app, and their completion is recorded automatically.

For the full requirements, read AML/CTF staff training requirements for real estate agencies.

Source: AML/CTF Act 2006, s 26F(4)(e); AUSTRAC training guidance

Week 5–6: Set up your CDD and screening process

Before 1 July 2026, you need your client identification and verification process ready to run on every transaction from day one.

That means:

Every staff member who takes on clients knows what information to collect and how to verify it
Your verification method is agreed and documented (in-person document inspection, video call, or electronic verification)
You have a process for clients who can't provide standard ID
Your screening against the DFAT Consolidated Sanctions List is set up and running
Your process for beneficial ownership identification (for company and trust clients) is documented

Run a dry-run with your team using a hypothetical client. Work through the intake form, the identity check, the sanctions screen. Find the gaps before 1 July rather than on the day.

For detailed CDD requirements, read Customer due diligence for real estate: a plain-English guide.

Week 6–7: Brief your team on red flags and SMRs

Before obligations commence, your team needs to know:

What suspicious activity looks like in real estate transactions
How to escalate concerns internally
That there is a Compliance Officer they report concerns to
That filing an SMR is a legal obligation when suspicion arises — not optional

You do not need a formal training session for this (though that helps). A team meeting that walks through the red flags list, who to call when something feels off, and what happens next is a meaningful step.

For the full SMR picture, read Suspicious matter reports for real estate agents: when and how to file.

July 1: Day one checklist

On 1 July 2026, your agency should be able to say:

We are enrolled with AUSTRAC and have our AUSTRAC Account Number
Our AML/CTF program is documented and approved by senior management
Our Compliance Officer is named and has been notified to AUSTRAC
All relevant staff have completed AML training before today
We are conducting CDD on every client from today
We are screening all new clients against the DFAT Consolidated Sanctions List
We have a process for identifying and reporting suspicious activity
Our record-keeping system is running

If you can say all of those things, you are in a good position. Document the date and keep that record.

After July 1: Ongoing obligations

Annual Compliance Report: Your first report covers 1 July–31 December 2026 and is due 31 March 2027. It summarises your program compliance, training conducted, SMRs and TTRs filed, and any issues identified.

Enrolment updates: Any change to your business must be notified to AUSTRAC within 14 days — new Compliance Officer, new address, new services, change in ownership.

Program review: Review your AML/CTF program whenever your risk profile changes — new services, new markets, new client types. At minimum every 3 years.

Independent evaluation: Your program must be independently evaluated at least every 3 years. The first evaluation deadline is staggered from 30 June 2029 to 31 December 2030 based on your AUSTRAC Account Number.

For the complete picture of your obligations, read the AUSTRAC Tranche 2 complete guide for real estate agencies.

This content is general information only and does not constitute legal or AML/CTF advice. For tailored advice, consult a licensed AML/CTF advisor. AML Simple is a compliance tool, not a law firm.

Want a personalised Tranche 2 readiness score for your agency? Take the free 5-minute Readiness Check → amlsimple.com/check