# AUSTRAC's Updated SMR/TTR Forms for Real Estate

Short answer: yes, the suspicious matter report (SMR) and threshold transaction report (TTR) forms
in AUSTRAC Online changed. New versions have been live since 1 July 2026. AUSTRAC's own description
of the change is that the redesigned forms reduce the overall amount of information reporting
entities need to provide and streamline the AUSTRAC Online experience — while asking for more
structured detail in a few specific areas. Whether it affects your agency right now depends on when
you enrolled with AUSTRAC, and for most agencies newly regulated under Tranche 2, it does.

This is general information, not legal advice. AUSTRAC's own guidance and the [Anti-Money
Laundering and Counter-Terrorism Financing Rules 2025](https://www.legislation.gov.au/F2025L01026/latest)
are the authoritative source for exactly what a report must contain. If anything here is unclear for
your agency's situation, check directly with [AUSTRAC](https://www.austrac.gov.au/new-austrac-online-reporting-forms-are-coming)
or your AML/CTF adviser before you file.

## Who's affected, and when

AUSTRAC runs the old and new forms in parallel for a transition period, not a single hard cut-over
date for everyone:

- If your agency **enrolled with AUSTRAC after 30 March 2026**, you're expected to use the new
  form from day one — there's no old-form option available to you.
- If your agency **enrolled by 30 March 2026**, you can keep using the pre-2026 form for now, and
  move to the new form whenever you're ready — up to a final deadline of 30 March 2029.

Real estate agencies newly regulated from 1 July 2026 use the new forms from day one, which means
this is worth checking now, not filing away for later.

## What's actually new

AUSTRAC describes the redesign as reducing the overall amount of information reporting entities
need to provide, with a more streamlined AUSTRAC Online experience — that's the headline direction.
But three areas got more structured, not less:

**Beneficial ownership detail.** Where a customer is a company, trust or other non-individual
entity, the new forms ask for more structured detail about who actually owns or controls it — not
just who's named on the contract. Per AUSTRAC's [guidance on ownership and control
structures](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/additional-guidance/determining-ownership-and-control-structures),
that underlying test hasn't changed: an individual is a beneficial owner if they directly or
indirectly own **25% or more** of the entity, *or* if they otherwise **control** it — control is its
own basis, independent of any ownership percentage, not a second route to the same 25% figure. If
your agency's CDD process
already identifies beneficial owners properly under that test, you're mostly re-using information
you should already be collecting.

**More structure around trusts.** If a customer transacts through a trust, both the new SMR and TTR
forms expect more specific detail about the trust itself — for SMR that includes the type of trust,
who the trustee is, and who the settlor, appointor, guardian or protector are, where relevant. For
beneficiaries specifically, the AML/CTF Rules 2025 draw a concrete line: **10 or fewer identifiable
beneficiaries** must be named individually; **more than 10** must be described by class instead (for
example, "the spouse and children of [the settlor]") — see [First AML's plain-English summary of
Part 9 reporting](https://www.firstaml.com/resources/the-laymans-guide-to-amlctf-rules-2025-part-9-reporting/)
for the detail spelled out further.

**Digital transaction detail, when it's relevant and known.** Where a matter involves an online or
digital channel, the new forms can ask for things like an IP address, device information, or the
software/app used. This isn't a blanket requirement to go and collect information you wouldn't
otherwise have — AUSTRAC's own framing is "if known" or "to the extent known." If a transaction was
entirely in-person with no digital element, this section simply won't apply.

Beneficial ownership and trust structure are the kind of information good CDD practice should
already be surfacing — captured in a more structured way so it's actually usable once it reaches
AUSTRAC. The digital-activity fields are different: for most agencies that's a genuinely new data
point, not something your existing CDD file is likely to already hold.

## What to do about it

A few practical steps:

1. **Check which form applies to you.** Log into AUSTRAC Online and confirm whether you're seeing
   the new SMR/TTR form, and check your enrolment date against the 30 March 2026 cut-over if
   you're not sure which track you're on.
2. **Make sure your AML/CTF compliance officer is aware of the changes.** They should factor it
   into how the agency reviews and files reports going forward.
3. **Make sure your CDD records already capture beneficial ownership and trust structure
   properly.** If they do, filling in the new form's ownership and trust fields is mostly a matter
   of transferring information you already hold.
4. **Don't guess at digital-transaction fields you don't have.** If the information genuinely
   isn't available or the matter wasn't digital, that's fine — these fields are framed as "if
   known," not mandatory regardless of circumstance.

How much this actually changes your day-to-day filing depends on how well your agency's records
already separate ownership, trust and beneficiary detail — for some agencies that's a small
adjustment, for others it's worth a proper review with your compliance officer before your next
report.

## Where AMLHive fits

AMLHive's SMR wizard currently captures trust type and beneficiary detail, using the same
individual/class split described above — it does not yet expose dedicated fields for trustee,
settlor, appointor, guardian or protector detail. The TTR wizard captures the new beneficial
ownership and online-activity fields and can identify a party as trust-related, but it also lacks
dedicated trust-structure fields. Entry in both wizards is manual right now, the same as AUSTRAC's
own form; we don't auto-populate report fields from your existing client screening and CDD records.
This isn't a substitute for checking the current AUSTRAC Online form yourself, and it doesn't change
who's responsible for the accuracy of what gets filed — that stays with your agency.

If you're setting up your AML/CTF program from scratch or want a clearer evidence trail for your
existing one, [start your 14-day free trial](/auth/signup) and see how AMLHive keeps client
screening, CDD and reporting evidence in one place.

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*This article is general information about AUSTRAC's SMR/TTR reporting forms as at August 2026. It
is not legal advice and does not replace your agency's own AML/CTF program, your AML/CTF compliance
officer's judgement, or direct guidance from AUSTRAC. Requirements can change — always confirm the
current form and its requirements directly in AUSTRAC Online before filing.*