Missed the 1 July 2026 AUSTRAC deadline? What still matters before 29 July

1 July 2026 has been and gone. If your agency didn't finish enrolling, didn't write a program, or hasn't started CDD yet, your obligations under the AML/CTF Act 2006 are already live. They apply whether you were ready or not.

That's the uncomfortable part. Here's the part that's still in your control: 29 July 2026 is the deadline to complete your AUSTRAC enrolment and notify AUSTRAC of your AML/CTF compliance officer, 28 days after commencement. That window is still open. What you do with it matters more than what happened on 1 July.

The fastest way to close the gap: one option for agencies that haven't finished is AML Simple. Sign up and enter your ABN (around 2 minutes) and your organisation profile pulls in automatically. Run the AUSTRAC Readiness Check (around 5 minutes) to see exactly where your agency stands against the obligations. Then run the AML/CTF Program Generator (around 15 minutes) to produce a documented starting point, consistent with AUSTRAC's Program Starter Kit structure. That sequence gets an agency from nothing to enrolled-with-a-documented-program in under half an hour of actual work.

What being behind actually means

Reporting entities are required to have an AML/CTF program, complete AUSTRAC enrolment, screen and identify clients, and keep records, from the date their obligations commenced. For real estate agencies caught by Tranche 2, that date was 1 July 2026.

Being behind doesn't mean your obligations haven't started. It means they started without you being ready for them. Every designated service your agency provides from 1 July onward, taking instructions to sell a property, accepting a deposit, is a point where CDD and record-keeping obligations already apply.

The penalty unit increased to A$364 from 1 July 2026. Civil penalties for contraventions of the Act can run up to A$36.4 million per contravention for a body corporate, and up to A$7.28 million per contravention for an individual. Failure to enrol carries a separate daily continuing penalty, up to A$21,840 per day for a body corporate and up to A$4,368 per day for an individual.

Those are maximum figures for serious, ongoing contraventions, not a prediction of what happens to an agency that's a few weeks late getting its program written. But they're the reason AUSTRAC treats enrolment and program obligations as live from day one, not aspirational.

What's still in reach before 29 July

Three things are genuinely still open right now:

• AUSTRAC enrolment. If you haven't submitted it, this is the priority. Enrolment is separate from having a finished program, and it's the faster of the two to complete.
• Compliance officer notification. AUSTRAC needs a named compliance officer within 28 days of commencement. For most agencies that's the principal or licensee in charge. This is a specific, bounded task, not an open-ended project.
• A documented AML/CTF program. Not yet approved, reviewed, or perfect. A documented starting point that your senior management can sign off, covering CDD, record-keeping, and reporting obligations, moves your agency from "obligations exist with nothing written down" to "obligations exist with a program in place."

What's not realistic to backdate: any designated services your agency has already provided since 1 July without CDD in place. Those obligations were live at the time, regardless of when the program document gets finished. The right move now is to close the gap forward, not to pretend the gap didn't happen.

How to move fast

Prefer to do it yourself? Here's what's involved, the same ground AML Simple's guided path covers:

1. Check your ABN and entity type match at abn.business.gov.au, then enrol directly through AUSTRAC Connect. Our guide on finding your AUSTRAC registration number covers the fields that most commonly get enrolment forms returned.
2. Nominate your compliance officer with full legal name and contact details, and notify AUSTRAC within the 28-day window.
3. Draft your written AML/CTF program covering CDD, record-keeping, transaction monitoring, and reporting obligations, structured against AUSTRAC's own Program Starter Kit.
4. Get sign-off from senior management on the program.
5. Start CDD on any client where a designated service is still in progress.

Each of those steps is real work, and doing them manually is a legitimate path. The guided path inside AML Simple compresses the same steps: ABN lookup, readiness check, and program generation, so you're not starting from a blank AUSTRAC form or a blank document.

If your agency provides multiple designated services or sits outside the Program Starter Kit's scope for smaller agencies (15 or fewer personnel, one designated service), the same principle applies: get enrolment and compliance officer notification done first, inside the 29 July window, then build out the fuller program.

For the complete list of obligations that apply from 1 July, read our AUSTRAC Tranche 2 complete guide. Once your program is in place, the next thing worth understanding is when you're required to lodge a suspicious matter report, covered in our SMR guide for real estate agents.

Being late isn't the same as being locked out. 29 July is still a real, workable deadline. Use it.