AUSTRAC AML/CTF Compliance for Bookkeepers: What You Need to Know in 2026

Many bookkeepers are asking: do Tranche 2 AML/CTF obligations apply to me? The answer depends on which services you provide. This guide explains when bookkeepers are captured and what you need to do.

Are bookkeepers captured by Tranche 2?

Bookkeeping alone — data entry, bank reconciliation, payroll — is not a designated service under Tranche 2. However, bookkeepers who also provide the following services ARE captured:

• Acting as a registered tax agent (preparing and lodging tax returns)
• Assisting with company formation or trust setup
• Managing client funds in trust accounts
• Providing BAS agent services that involve significant financial transactions

If you are a BAS agent or registered tax agent, you are very likely captured.

What obligations apply to captured bookkeepers?

If you are captured, you must enrol with AUSTRAC by 29 July 2026, develop an AML/CTF program, conduct KYC on all clients before providing designated services, and screen against sanctions and PEP lists.

KYC for bookkeeping clients

For individual clients: verify name, date of birth and address using a government-issued ID. For company or trust clients: verify the entity and all directors/trustees. This can be done electronically via biometric ID verification — your client receives a link and completes the check in minutes on their phone.

Risk assessment for bookkeeping clients

AUSTRAC requires a risk assessment for every client. Bookkeeping clients who are cash-intensive businesses (cafes, hospitality, retail) or who operate internationally are treated as higher risk and require closer monitoring.

Practical steps to get compliant

1. Determine if you provide any designated services
2. Enrol with AUSTRAC by 29 July 2026
3. Write or purchase an AML/CTF program template
4. Appoint a compliance officer (can be yourself)
5. Run KYC on all new clients before starting work
6. Screen all clients against sanctions lists
7. Train your staff on AML obligations

Related reading: AML compliance software cost guide · Choosing AML compliance software · AUSTRAC Tranche 2 complete guide · Frequently asked questions