AUSTRAC enrolment penalties: what accounting firms need to do now

AUSTRAC has begun issuing enrolment penalties to businesses in the accounting sector. Here is how to check whether your firm must enrol and what to do next.

AUSTRAC has begun issuing financial penalties to businesses in the accounting sector for failing to enrol. If your firm provides designated services with a geographical link to Australia, enrolment is a legal obligation.

For accounting firms still deciding whether the AML/CTF reforms apply to them, this is a reason to resolve that question now.

The practical task is to identify the services your firm actually provides, confirm whether enrolment is required and make sure someone owns the next steps.

AUSTRAC has moved from information notices to penalties

On 28 August 2026, AUSTRAC announced it was issuing section 167 notices to businesses that appeared to be providing designated services without being enrolled. Accountants were among the professions identified.

These were formal requests for information to help AUSTRAC determine whether businesses were regulated and meeting their obligations.

On 30 September 2026, AUSTRAC confirmed it had begun issuing infringement notices to businesses in the accounting, real estate and jewellery sectors that it believed had failed to enrol within the required timeframe.

The infringement amounts announced were:

AUSTRAC also stated that penalties can accrue daily and that further enforcement action is planned for ongoing non-compliance.

These figures relate to the infringement notices announced. They should not be treated as a cap on every possible consequence of non-compliance.

Does every accounting firm need to enrol with AUSTRAC?

No. The requirement depends on the services your business provides.

An accounting firm generally needs to enrol if it provides one or more designated services with a geographical link to Australia, subject to any applicable exemption.

Activities worth checking against AUSTRAC’s professional designated services guidance include:

• Helping establish or restructure companies or trusts.
• Providing a registered office address or principal place of business address.
• Assisting with transactions involving the sale, purchase or transfer of companies, legal arrangements or real estate.
• Certain activities involving client property or arranging equity or debt financing.

These are prompts for a service review. The precise activity, your role and the circumstances determine whether a designated service is being provided.

For example, a firm that mainly prepares tax returns may also help clients establish companies. That additional work needs its own assessment. Describing the practice as a “tax firm” does not settle the question.

When should accounting firms have enrolled?

For newly regulated businesses providing relevant designated services from 1 July 2026, the enrolment deadline was 29 July 2026.

The Tax Practitioners Board confirms this timing in its AML/CTF guidance for tax practitioners.

Businesses that start providing a designated service later must generally apply to enrol no later than 28 days after the day they start providing it.

That enrolment window does not postpone other AML/CTF obligations that apply when providing the service.

What should your firm do if it has not enrolled?

1. Review the services your firm actually delivers

Use recent engagements, your service list and recurring arrangements to identify potentially regulated work. Include services performed occasionally or as part of a broader engagement.

Record the service, the relevant designated service category and the reasons for your conclusion. Where the position is unclear, seek clarification from AUSTRAC or advice specific to your circumstances.

2. Complete the business enrolment

If enrolment is required, follow AUSTRAC’s enrolment process.

Creating an AUSTRAC Online user account is only part of that process. You also need to complete and submit the business enrolment form. Keep the submission receipt and subsequent enrolment confirmation with your compliance records.

Assign a person to complete the process and a date to check its status. An unfinished application should remain an open action.

3. Respond promptly to any AUSTRAC notice

If your firm has received a notice, read what it requires and identify the response deadline. Give responsibility to a named person and retain the response and supporting records.

Do not assume completing enrolment also answers a separate information request. Address each requirement in the notice.

4. Put your ongoing compliance arrangements into practice

Enrolment is one part of your firm’s obligations. It does not establish that your firm is fully compliant.

Your arrangements also need to address the applicable requirements for your AML/CTF program, customer due diligence, personnel due diligence, training, reporting and record keeping.

A useful internal check is to ask: who carries out each task, when do they do it and where is the evidence kept?

Common questions about AUSTRAC enrolment for accountants

Do accountants need to enrol or register with AUSTRAC?

Accountants providing designated services generally need to enrol. Registration is a separate process that typically applies to remittance and certain virtual asset service providers.

Should we wait for AUSTRAC to contact us?

No. Your obligation depends on the services you provide. A letter or notice from AUSTRAC is not what creates it.

What if we are unsure whether our services are covered?

Compare the actual work with AUSTRAC’s designated services guidance and resolve any uncertainty promptly. AUSTRAC has expressly encouraged businesses to contact it for help understanding their obligations.

Bring your firm’s AML/CTF work into one place

Once your firm has confirmed its obligations, the next challenge is making compliance part of everyday work.

Nelvo is built for Australian accounting firms, with tools to manage AML/CTF programs, client risk and verification, staff training, and compliance evidence.

Explore Nelvo to see how it can help your firm organise that work and maintain supporting records.

This article reflects guidance available on 15 October 2026. Whether your firm is regulated depends on its services and circumstances.