AUSTRAC Annual Compliance Report: what real estate agents need to know

Your agency builds its AML/CTF program, trains staff, and does CDD on every client. But there is one obligation that catches many agencies off-guard: the Annual Compliance Report (ACR).

Every enrolled reporting entity — including real estate agencies — must submit an ACR to AUSTRAC each year. Miss it, or submit an inaccurate one, and you are exposed to exactly the kind of penalty the law was designed to enforce.

The good news: if your records are in order, the ACR is mostly a structured summary of work you have already done. AML Simple tracks the underlying data throughout the year so there is nothing to reconstruct at reporting time.

The fast path: let the platform track it as you go

AML Simple logs every compliance action your agency takes — CDD completed, training records, risk assessments updated, SMRs lodged. When your ACR is due, the data is already there.

Three things that make ACR preparation straightforward in the platform:

Audit trail — every CDD verification, sanctions screen, and training completion is timestamped and stored against your agency record
Program version history — if you updated your AML/CTF program during the year, those changes are recorded
SMR and TTR records — suspicious matter reports and threshold transaction reports you lodged during the year are accessible from your account

When it is time to file your ACR, you are summarising records that already exist — not scrambling to reconstruct them.

Start your AML program and begin building your compliance record from day one: amlsimple.com.

What is the Annual Compliance Report?

The ACR is a self-assessment report submitted to AUSTRAC by all enrolled reporting entities. Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, s 47, enrolled entities must report on their compliance with the Act during the preceding financial year.

For real estate agencies under Tranche 2, the ACR obligation applies from the first full reporting period after enrolment. The report is submitted through AUSTRAC Online, AUSTRAC's secure reporting portal.

The ACR is not a form you fill in from scratch each year. It draws on the records and activities your agency has maintained across the year: your program, your training records, your CDD activity, and any suspicious matter or threshold transaction reports you lodged.

What does the ACR cover?

AUSTRAC's ACR template asks enrolled entities to report on several areas. For real estate agencies, the main areas are:

1. AML/CTF program compliance

You will need to confirm whether your agency has a current, documented AML/CTF program that meets the requirements of the Act, and whether the program was reviewed and updated during the year.

If your program was not updated since you first built it, that is worth noting before you submit — particularly if your business circumstances changed (new staff, new services, new transaction types).

2. Staff training

You will need to confirm that staff who perform AML-relevant duties received AML/CTF training before performing those duties, and that training records are maintained. See AUSTRAC's guidance on staff training obligations under s 26F(4)(e) of the Act.

3. CDD activity

The ACR asks about your customer due diligence activity — whether your agency applied appropriate CDD to customers, and whether enhanced CDD was applied where required (e.g. for high-risk transactions or customers).

4. Suspicious matter and threshold transaction reports

AUSTRAC will ask whether your agency lodged any suspicious matter reports (SMRs) or threshold transaction reports (TTRs) during the year. If you did, those lodgements should already be on record. If you did not, you will confirm that no reportable activity occurred.

5. Independent review

For agencies with a risk:medium or risk:high profile, AUSTRAC expects your AML/CTF program to be independently reviewed at appropriate intervals. The ACR may ask whether an independent review was conducted during the reporting period and what the findings were.

Understanding what your AML/CTF program must include is the foundation for preparing an accurate ACR — the report draws directly on your program documentation.

When is the ACR due?

The ACR covers the financial year (1 July to 30 June) and is submitted through AUSTRAC Online within the period AUSTRAC specifies — typically a window of several months after the financial year ends. AUSTRAC notifies enrolled entities when the ACR window opens.

For real estate agencies enrolled ahead of the 1 July 2026 Tranche 2 commencement date, the first ACR will cover the 2026–27 financial year, due in 2027.

Check AUSTRAC Online for the current lodgement window each year.

What happens if you miss it?

Failure to lodge an ACR, or lodging a materially inaccurate one, is a breach of your obligations under the Act. AUSTRAC has broad enforcement powers — including infringement notices, civil penalty orders, and enforceable undertakings — that apply to reporting entities that fail to meet their reporting obligations.

This is not a theoretical risk. AUSTRAC has used its audit and enforcement powers actively since Tranche 1 reforms and has signalled it will apply the same approach to Tranche 2 reporting entities.

Practical tips for ACR preparation

Whether you are using AML Simple or preparing manually, these habits make ACR time much less stressful:

Keep your program current. If your agency changed services, transaction types, or team structure during the year, update your AML/CTF program at the time — not at ACR time.
Record training completions immediately. Don't reconstruct training records from memory. Log them as they happen.
Lodge SMRs and TTRs promptly. These records are part of your ACR. Delayed lodgement creates a gap you will need to explain.
Date-stamp everything. AUSTRAC reviewers look at when things happened, not just whether they happened.

Prefer to do it yourself?

Here is the same information as a preparation checklist for agencies managing compliance manually.

Before the ACR window opens, confirm you have:

A current, documented AML/CTF program (reviewed in the past 12 months if your risk profile warrants it)
Training records for every staff member who performed AML-relevant duties during the year
CDD records for every customer — including the basis for any enhanced CDD applied
A record of every SMR and TTR lodged during the year (or a documented confirmation that none were required)
Notes from any independent review conducted during the year (if applicable)

When the AUSTRAC Online window opens:

Log in to AUSTRAC Online using your registered entity credentials
Navigate to the Annual Compliance Report section
Work through each section, drawing on the records above
Submit and retain a copy of your submission

The same data AML Simple tracks automatically throughout the year is the data you need to gather manually if you manage compliance without a platform.

This content is general information only and does not constitute legal or AML/CTF advice. AML Simple is a compliance workflow tool. For advice specific to your agency, consult a qualified AML/CTF compliance professional.