What this will mean for you
From 1 July 2026, accounting practices across Australia are required to comply with new Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws, regulated by AUSTRAC — Australia’s financial intelligence agency. That includes us, and by extension you, but only for certain services.
What’s changing?
Accountants will be covered by Australia’s anti-money laundering laws for the first time from 1st July 2026. This means we now have legal obligations to verify who our clients are and to monitor for certain types of suspicious activity when we provide specific services.
That’s the short version. Naturally we will contact you if and when you are affected. For more details and answers to some common questions, please read on.
Why is this happening?
We’ve asked ourselves the same question many times! Australia is bringing its laws into line with international standards set by the Financial Action Task Force (FATF). Accountants, lawyers, real estate agents, and dealers in precious metals are being brought under the regime because in some contexts these professions can be exploited by criminals to launder money — often without the service provider even realising. Australia has been slow to extend AML/CTF compliance to the accounting profession, relative to other countries, so there was always a sense of inevitability about it.
Will this affect you?
It will affect some of you, but for the most part it will be in a straightforward way. You may notice some changes in how we work with you — particularly when we provide certain services. In practice, this may include requests for identification documents, additional questions about the purpose of a transaction, and requests for documentation before some services can be provided. These steps are required by law — they’re not something we’ve chosen to introduce. For most of our clients, the process will be simple and quick.
Does this apply to all services?
No. The rules only apply when we provide certain services known as ‘designated services’. Preparing a standard tax return or providing general tax advice, for example, is not a designated service on its own.
What types of services are covered?
The rules apply to specific professional services that involve financial transactions or the creation of legal structures. Some examples of services that may be covered include:
- Assisting with buying, selling, or transferring real estate
- Assisting with buying, selling, or transferring a company or trust
- Holding, managing, or controlling client money, accounts, or property
- Assisting with equity or debt financing transactions
- Creating or restructuring companies, trusts, or other legal arrangements
- Acting as (or arranging for someone to act as) a director, secretary, trustee, or partner on your behalf
- Providing a registered office or business address on behalf of a client
If we assist with services like these, the AML/CTF rules apply.
What if we only provide you with tax return services?
Preparing a standard individual tax return is generally not a designated service on its own. But if we also help you with things like setting up a company, managing a trust, handling client money, or assisting with the sale of a business, those activities are designated services — and the requirements apply. We can confirm which of your services are affected.
Identity verification
Under the new laws, we’re legally required to verify the identity of every client before providing a designated service. This is called customer due diligence. It’s not optional — it’s a legal obligation, and it applies to both new and existing clients. Banks and financial institutions already follow similar processes.
What ID will be required?
Typically, you’ll need to provide your full name, date of birth, and residential address. We’ll verify this against a government-issued photo ID such as a driver’s licence or passport. For businesses, trusts, or other structures, we may also need information about directors, beneficial owners, or trustees.
In many cases, we may already have some of the key documents — trust deeds, company constitutions, ASIC extracts, and similar records are sometimes kept at our office. Where that’s the case, we’ll work with whatever records we already have and only ask you for anything that’s missing or needs updating. The main item you’re most likely to need to provide is a current photo ID.
We understand this might feel unnecessary, especially if we’ve had a long relationship with you over many years. The new laws, however, require us to have formal identification on file for all clients we provide designated services to — not just those who are new to us.
The level of checks required depends on the risk associated with the service or transaction. For most individual Australian residents using straightforward accounting services, the process will be simple. In some situations — such as complex structures, international elements, or higher-risk transactions — we may need to collect additional information. A higher level of checking doesn’t mean anything is wrong. It’s a standard part of the process.
We may also be required to ask where your money comes from
In certain situations — particularly where an engagement involves large sums, complex structures, or international elements — the law requires us to ask about the source of funds for a transaction and how your overall wealth has been accumulated. These are standard risk-assessment questions required by the legislation, not a reflection of any concern about you.
What happens if I don’t provide ID?
We may not be able to provide you with certain services. Under the law, we are compelled to complete identity verification before providing a designated service. If we proceed without doing so the penalties for us are severe.
Is my personal information safe?
Yes. We’re required to keep your information secure and only use it for the purposes required by law. AML/CTF records must be retained for at least seven years, and we must comply with the Privacy Act 1988 in how we store and handle your data. Your information won’t be shared with anyone outside of what the law requires.
Will you be monitoring my transactions?
We have an obligation to conduct ongoing due diligence on the services we provide to you. This means we’ll keep your information up to date and may ask you to confirm or update details from time to time. We’re not auditors and are not legally required to provide any kind of assurances. But if anything unusual comes to our attention in the course of providing services, we’re legally required to assess it. This is a standard obligation that applies to everyone — it’s not a reflection of any concern about you personally.
Is this a one-off thing, or ongoing?
The identity verification is largely a one-off process. But the obligations are ongoing — we’ll need to keep your information current and may ask you to update your details from time to time. If your circumstances change significantly — for example, you move overseas or restructure your business — we may need to do additional checks.
Will you need to report certain matters to AUSTRAC?
Yes. If we form a suspicion that a transaction or activity may be related to money laundering, terrorism financing, or other serious crime, we’re legally required to report it to AUSTRAC. This is called a suspicious matter report. It may not necessarily mean anything is wrong, but once again, the penalties for us in not erring on the side of caution are onerous.
Will you tell me if a report has been made?
Under the rules we’re not permitted to. Disclosing that a suspicious matter report has been made (or is required to be made) is a criminal offence known as “tipping off.” This applies to every accountant in Australia, not just us. If we seem unable to discuss certain aspects of a matter, please understand this may be because we’re bound by these legal restrictions.
You provide my company’s registered office. Does this affect me?
Yes. Providing a registered office or business address is classified as a designated service under the new AML rules. This means we’ll need to complete identity checks for any company using our office as the registered address.
Given that there is no legal or practical requirement to use an accountant as a registered office (it’s more of a legacy practice from a previous era) we will be contacting those affected to change their registered office to a personal address.
In cases where you continue to use us as your registered office, we’ll be required to complete identity checks and will do so as part of your regular annual engagement. Because we may already have many of the required documents on file, the process should be relatively quick.
What about if you operate across multiple entities?
Each entity that requires a designated service will need its own identity verification. However, where individuals are involved across multiple entities (for example, you’re a director of two companies and a trustee of a trust), your personal identity only needs to be verified once. We’ll coordinate the process across your structures to keep things as efficient as possible.
Will this cost me more?
The short answer is yes, unfortunately, but not always a lot more. We are now required to invest in compliance systems, staff training, identity verification processes, and ongoing monitoring — all of which have costs. The extent to which those costs are reflected in your fees will depend on the services you use, but at the very least the identity verification process requires the use of a third-party service that charges us a fee per check, and we will need to pass that on. This is a compliance burden that has been imposed on us and given the considerable number of clients affected, we regretfully have no option but to recover the associated costs.
Do I need to take any action right now?
No immediate action is required. However, from 1 July 2026, you may be asked to provide identification or additional information before we can proceed with certain services. Providing this promptly will help make sure there are no delays. If you’ve already been asked to complete an onboarding form or provide ID, that’s this process in action — and we appreciate your cooperation.
AUSTRAC has published detailed guidance on its website at austrac.gov.au. But we also invite you to contact us if you have any questions, particularly as it concerns which of our services are affected and exactly what you’ll need to provide.
