AUSTRAC Enrolment for TCSPs: What's Required
Australian trust and company service providers must be enrolled with AUSTRAC under Tranche 2, which commenced on 1 July 2026. Here's what enrolment involves.
Every Australian trust and company service provider (TCSP) that provides a designated service must be enrolled with AUSTRAC — Tranche 2 commenced on 1 July 2026. Enrolment is a legal prerequisite under the AML/CTF Act 2006: operating a regulated business without enrolling exposes the firm to civil penalties of up to $18.5 million per contravention. Here is what enrolment involves, who must complete it, and what else must be ready alongside it.
Who must enrol with AUSTRAC before 1 July 2026?
Any business providing one or more designated TCSP services in Australia must enrol. Under the Tranche 2 amendments to the AML/CTF Act 2006, TCSP designated services include: - Trust administration — acting as trustee, managing trust assets, or administering discretionary or unit trusts for a fee - Company and trust formation — incorporating companies or establishing trusts on behalf of clients - Nominee director and nominee shareholder services — providing a person to act as director or shareholder on behalf of an undisclosed beneficial owner - Registered office and business address services — providing a registered address for an entity's public records - Company secretarial services — acting as company secretary or managing statutory filings on behalf of clients If your firm provides any of these services commercially, enrolment is mandatory — even if the TCSP work represents a small portion of your overall practice.
How do you enrol with AUSTRAC?
Enrolment is completed through AUSTRAC Online — AUSTRAC's secure portal. The process takes approximately 20–30 minutes with details prepared in advance: 1. Create or log into your AUSTRAC Online account — the principal or an authorised officer of the business must complete the enrolment 2. Select your designated services — choose the TCSP services your business provides from the Tranche 2 designated services list 3. Provide business details — legal name, ABN, principal place of business, and contact information 4. Nominate your AMLCO — the person accountable for your AML/CTF programme 5. Submit — AUSTRAC issues an enrolment acknowledgement; retain this for your records AUSTRAC recommends completing enrolment before the deadline rather than on 1 July itself, to allow time to resolve any technical issues.
What else must be in place by 1 July 2026?
Enrolment is necessary but not sufficient. The AML/CTF Act 2006 requires every enrolled reporting entity to have a compliant written AML/CTF programme in place from the moment Tranche 2 takes effect. For TCSPs, the programme must include: - Part A — governance: AMLCO appointment, customer acceptance policy, and independent review schedule - Part B — CDD procedures: identification, verification, beneficial ownership mapping, PEP and sanctions screening, and ongoing monitoring - ML/TF risk assessment — a documented assessment calibrated to the TCSP sector's elevated inherent risk profile - Staff training — completed training records for all staff with AML/CTF responsibilities Firms that enrol but have no programme are still non-compliant. AMLify for TCSPs guides firms through programme setup in under 35 minutes.
Key Takeaways
- Every TCSP providing a designated service must be enrolled with AUSTRAC — Tranche 2 commenced on 1 July 2026; operating unenrolled risks civil penalties of up to $18.5 million per contravention
- Enrolment is completed through AUSTRAC Online in approximately 20–30 minutes; the principal or an authorised officer must complete it
- Designated TCSP services include trust administration, company and trust formation, nominee arrangements, registered office, and company secretarial services
- Enrolment alone is not enough — a written AML/CTF programme covering Part A, Part B, an ML/TF risk assessment, and staff training must also be in place from 1 July 2026
- Start programme setup now — AMLify for TCSPs generates a compliant programme in under 35 minutes
Frequently Asked Questions
Q: Does every TCSP have to enrol, even sole practitioners?
Yes. The AML/CTF Act 2006 does not exempt sole practitioners or small businesses. If you provide a designated TCSP service commercially — forming companies for clients, acting as a nominee director, or administering a trust — the obligation to enrol and have a written programme in place applies regardless of the size of your practice.
Q: What happens if a TCSP misses the 1 July 2026 enrolment deadline?
Providing a designated service without being enrolled is a civil penalty provision under the AML/CTF Act 2006. AUSTRAC can issue infringement notices, seek civil penalty orders of up to $18.5 million per contravention, or accept an enforceable undertaking. AUSTRAC has indicated that Tranche 2 DNFBPs will receive active supervision from 1 July 2026 — there is no announced grace period.
Q: Is a written AML/CTF programme required at enrolment, or can it be completed after?
The AML/CTF Act 2006 requires a compliant programme to be in place from the date Tranche 2 obligations take effect — 1 July 2026. Enrolment is a separate step that must also happen before that date. AUSTRAC does not provide a grace period for programme completion after enrolment; if AUSTRAC reviews your business after 1 July 2026 and finds no programme, the absence is itself a contravention.
This is general information only and not a substitute for legal advice.