Missed the deadline?

The AUSTRAC deadline has passed. You are not off the hook.

Enrolment was due 29 July 2026. If your firm provides designated services and you have not enrolled, the obligation has not gone away — it is running against you every day. Here is exactly what to do, in the order that matters.

Start catching up Talk to someone first

First, the honest position

Late is not the same as too late

A missed deadline is not a door that closed. The obligation to enrol continues for as long as you provide designated services, and every day unenrolled is a day of non-compliance you can stop accruing today.

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Failing to enrol is itself a breach — not a paperwork delay. The AML/CTF Act carries civil penalties reaching into the tens of millions for serious contraventions. What matters now is that the breach stops, and that you can show when and how you fixed it.

The firms that come out of this well are not the ones who were perfect. They are the ones who can show a regulator a clear record: this is when we realised, this is what we did, this is the date each thing was in place. That record is worth building from today.

The catch-up order

Four things, in this sequence

Enrol with AUSTRAC — today, not after the program is written

Enrolment and your AML/CTF program are separate obligations. People delay enrolling because the program is not finished, which leaves them in breach of both instead of one. Enrol first. It takes an afternoon.

Appoint your AML/CTF Compliance Officer

This must be a real person at management level with the authority and resources to do the job, and they must be notified to AUSTRAC. It cannot be an outsourced provider, and it cannot be a junior. In a small firm it is usually the principal.

Document your program and your ML/TF risk assessment

Not a downloaded template with your name on it — a program that reflects what your firm actually does, which customers it deals with, and how it decides who is high risk. CompliDesk builds this from a structured interview rather than a blank page.

Start verifying customers — new ones first, then the back-file

Every customer receiving a designated service needs customer due diligence. Do new customers from today so the problem stops growing, then work backwards through those you onboarded while unenrolled.

The part everyone underestimates

The back-file is the real work

Enrolling takes an afternoon. Writing the program takes a day. Verifying every customer you have already onboarded is the piece that stalls firms for months — and it is the piece that a regulator will look at first.

✓ Do it yourself in CompliDesk

Send each customer a secure link. They upload their ID, we verify it, screen them against sanctions and PEP lists, and produce the risk rating and evidence pack. From $39/month with checks included.

✓ Or hand the whole thing to us

Our team contacts your customers, collects and verifies their documents, screens them, risk-rates them against your program and hands you a finished file to sign off. You do nothing but refer the name.

See the done-for-you service Or just see pricing

Questions

What firms ask when they realise they are late

Yes. The enrolment obligation does not expire with the deadline. If your firm provides designated services under the AML/CTF Act, you are required to be enrolled with AUSTRAC, and that requirement continues every day you are not. Enrolling late is better than not enrolling.

Failing to enrol on time is a breach of the Act. Whether that leads to enforcement is a matter for AUSTRAC, and its published approach has emphasised working with businesses that are making a genuine effort to comply. Enrolling and getting your program in place is the step that moves you from ongoing breach to remediation. We are not lawyers and this is not legal advice — if you have been trading unenrolled for some time, get advice.

Then your clock is different: you must enrol within 28 days of first providing a designated service. If that date has also passed, the position is the same as above — enrol now.

No. Enrolment and your program are separate obligations. You should enrol without waiting, then put the program, the Compliance Officer appointment and your customer due diligence process in place. Do not delay enrolment because the rest is not ready.

If you have been providing designated services since 1 July 2026 and have not enrolled, appointed a Compliance Officer, documented a program or done CDD on your customers, you are behind on four things rather than one. The order that matters is: enrol, appoint, document, then start verifying. Each one is achievable in days, not months.

Customers you took on while unenrolled still need customer due diligence. That is called back-file remediation and it is a normal part of catching up. It is usually the largest single piece of work, and the one most worth outsourcing.

CompliDesk is compliance software, not a law firm. Nothing on this page is legal advice. If you have been providing designated services unenrolled for an extended period, speak to a lawyer as well as getting your systems in order.