25 Days to Go: What Australian Law Firms Must Do Before the Tranche 2 Enrolment Deadline

With just 25 days until the 31 March 2026 enrolment deadline, Australian law firms face the most significant compliance shift in a generation. The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 is about to extend its reach to tens of thousands of new reporting entities — and legal practitioners are at the centre of that change.

The clock is ticking. Firms that have not yet begun their compliance preparations risk missing the initial enrolment window and exposing themselves to regulatory scrutiny from AUSTRAC (Australian Transaction Reports and Analysis Centre) at the worst possible time.

What Happens on 31 March 2026

The 31 March 2026 date is a critical milestone under the AML/CTF Amendment Act, passed by the Australian Parliament on 29 November 2024. From that date, enrolment with AUSTRAC opens for the estimated 80,000–90,000 new reporting entities brought into the regime under what is widely known as "Tranche 2" - including lawyers, accountants, real estate agents, and other designated non-financial businesses and professions (DNFBPs).

For existing reporting entities such as banks and financial services firms, 31 March also triggers updated obligations, including revised customer due diligence (CDD) requirements and changes to AML/CTF programme standards.

New entities, those being captured for the first time, have until 29 July 2026 to complete their AUSTRAC enrolment. Full Tranche 2 obligations, including the requirement to have an AML/CTF programme in place, commence on 1 July 2026.

AUSTRAC's January 2026 Guidance: What It Covers

In January 2026, AUSTRAC released sector-specific guidance for lawyers and accountants, providing practical direction on how the new obligations will apply to common legal services. The guidance addresses which services trigger reporting obligations, how to conduct simplified versus enhanced CDD depending on client risk, and what a compliant AML/CTF programme should look like for a legal practice.

Key areas covered include: trust account management and its intersection with AML/CTF obligations; obligations when acting on property transactions or business sales; customer identification and verification requirements for individuals and corporate clients; and ongoing monitoring obligations.

The guidance does not alter the legislative deadlines, but it signals AUSTRAC's expectation that firms will have begun implementation work well before July.

What Law Firms Should Be Doing Right Now

With 26 days to enrolment opening, the immediate priority is internal readiness. Firms should be completing their ML/TF (money laundering and terrorism financing) risk assessments, appointing a designated AML/CTF compliance officer, and drafting or finalising their AML/CTF programme documentation.

For all law firms, the challenge is often resourcing. Building a compliance function from scratch while maintaining client work is demanding, and many firms are now looking at technology and specialist support to bridge the gap. Client Lifecycle Management Platforms like Legl, which help law firms manage client onboarding and AML compliance workflows, are among the tools firms are looking to as they build out their compliance infrastructure ahead of these deadlines.

The Law Council of Australia has urged firms to treat these obligations seriously and not to delay, noting that AUSTRAC has historically taken enforcement action against entities that fail to enrol or maintain compliant programmes.

Key Takeaways

• 31 March 2026: AUSTRAC enrolment opens for new reporting entities, including law firms. Mark this date.
• 1 July 2026: Full Tranche 2 obligations commence, including having an AML/CTF programme in place.
• 29 July 2026: Deadline for new entities to complete AUSTRAC enrolment.
• AUSTRAC's January 2026 guidance provides sector-specific direction for lawyers — read it now if you haven't.
• Start with your risk assessment: This is the foundation of your AML/CTF programme and must precede everything else.

Looking Ahead

Australia's Financial Action Task Force (FATF) mutual evaluation is scheduled for 2026, adding further urgency to the government's push for full implementation. AUSTRAC is expected to issue additional compliance resources and potentially host industry briefings in the lead-up to 1 July. Firms should monitor AUSTRAC's website and sign up for regulatory updates. Those that move quickly on enrolment and programme development will be best placed when supervisory activity inevitably increases in the second half of the year.

Sources

• AUSTRAC: https://www.austrac.gov.au
• Attorney-General's Department AML/CTF reform information: https://www.ag.gov.au
• Law Council of Australia: https://www.lawcouncil.asn.au
• AML/CTF Amendment Act 2024

‍