There are two ways an agency gets the post-commencement period wrong, and they are opposites.

The first is assuming you are exempt because "we are only small" or "we mostly do rentals". The second is the reverse: over-engineering a compliance program for obligations that may not apply to the services you actually provide. Both come from the same gap - nobody has clearly told principals how to work out where they stand.

So before anything else, the right move is not to download a template. It is to point the compass and read it honestly.

### The Tranche 2 scope compass
*Most agencies are not asking how to comply. They are quietly unsure whether the regime even applies to them. Start with the service, not the job title.*

| 1. Start with the service | 2. Almost certainly captured |
| :--- | :--- |
| • What did you actually do for the client?<br>• Brokering a sale, purchase or transfer?<br>• Selling property you developed? | • Sales agents and their agencies<br>• Buyer's agents acting on a purchase<br>• Developers selling their own stock |

| 3. Different service, check it | 4. Outside the real estate definition |
| :--- | :--- |
| • Pure property management and rent roll<br>• Strata and body corporate admin<br>• Valuations or advice with no brokering | • Dwellings not attached to land<br>• Resident owns the dwelling, leases the land<br>• e.g. some caravan parks and retirement villages |

**Flow:** Name the service ➔ Is it brokering a sale or transfer? ➔ Does it happen from 1 July? ➔ Captured: enrol. Not captured: record why

*Takeaway: If you broker the sale, purchase or transfer of real estate as a business, you are almost certainly captured from 1 July 2026 - and if you think you are not, the burden is on you to show it.*

---

## Question 1: Do you broker the sale, purchase or transfer of real estate?

This is the heart of it. AUSTRAC describes the real estate designated service as brokering the **sale, purchase or transfer of real estate** as part of a business. (Source: AUSTRAC, "Real estate designated services", retrieved 14 June 2026)

If that is what you do for clients, you are almost certainly a reporting entity from **1 July 2026**. AUSTRAC has been explicit that the obligations apply to **real estate agents, buyer's agents and property developers** selling their own stock.

Note what the test is built on: the *service*, not the size of the business and not the job title on the door. A two-person independent agency that brokers sales is captured in the same way a national franchise is. There is no "small business" carve-out from the designated service itself.

---

## Question 2: What about property management and rent rolls?

This is where a lot of agencies talk themselves into the wrong answer in either direction.

Managing a rental property on behalf of a landlord - collecting rent, arranging repairs, running the lease - is a **different service** from brokering the sale, purchase or transfer of real estate. AUSTRAC's own real estate starter kit is written for businesses whose **only** designated service is brokering, which tells you property management is not treated as the same thing. (Source: AUSTRAC, "Real estate program starter kit", retrieved 14 June 2026)

> The trap is the mixed agency. If you do sales *and* property management, the sales side pulls you into the regime - you do not get to point at the rent roll and call yourself exempt.
>
> **— The distinction principals most often get wrong**

So the honest reading is: a pure property management business with no brokering may sit outside the designated service, but almost every full-service agency does some brokering - and that is enough. When in doubt, map each service line separately rather than judging the business as a single block.

---

## Question 3: Are you sure you are outside the real estate definition?

There is a genuine edge to the scope, and it is narrower than people hope. AUSTRAC's definition of real estate **excludes** certain interests - notably dwellings that are not attached to land, where the resident owns the dwelling but leases the land underneath it. (Source: AUSTRAC, "Real estate designated services", retrieved 14 June 2026)

In practice that can cover some caravan parks and certain retirement village arrangements. A business dealing only in those interests may not be providing a real estate designated service at all.

But treat this as the exception that proves the rule. It is a specific structural carve-out, not a general "we are a bit different" defence. If your exemption argument depends on a technicality, write it down and be ready to defend it - which is exactly what Question 5 is about.

---

## Question 4: If you are captured, what is the actual minimum?

Here is the part that should lower the temperature. Being captured does not mean building a bank's compliance department. AUSTRAC's summary of obligations for newly regulated entities comes down to a short, concrete list. (Source: AUSTRAC, "Summary of AML/CTF obligations for tranche 2 entities", retrieved 14 June 2026)

*   **Enrol** as a reporting entity with AUSTRAC
*   Adopt a written **AML/CTF program** appropriate to your business
*   Appoint an **AML/CTF compliance officer**
*   Carry out **customer due diligence** - verify who your buyers and sellers are and risk-rate the transaction
*   Be ready to **report suspicious matters** and to keep the required records

And the dates are not negotiable. The designated services took effect on **1 July 2026**. If you provide them, you must apply to **enrol by 29 July 2026**, and notify AUSTRAC of your compliance officer by 29 July 2026 or within 14 days of enrolling, whichever is later. (Source: AUSTRAC, "Enrol with us" and "AML/CTF compliance officer", retrieved 14 June 2026)

### The 5-minute readiness verdict
*Once you know you are captured, the minimum is smaller than most principals fear - but the dates are fixed and the evidence has to exist.*

| 1. Stand these up | 2. Know your customer |
| :--- | :--- |
| • Enrol with AUSTRAC<br>• Adopt a written AML/CTF program<br>• Name an AML/CTF compliance officer | • Verify buyers and sellers<br>• Risk-rate the transaction<br>• Keep the records |

| 3. Be ready to report | 4. Dates that bind |
| :--- | :--- |
| • Spot suspicious matters<br>• Know the reporting pathway<br>• Train staff to escalate | • Services captured since 1 July 2026<br>• Enrol by 29 July 2026<br>• Notify officer by 29 July or +14 days |

**Flow:** Enrol the entity ➔ Adopt the program ➔ Appoint and notify the officer ➔ Train, verify, be ready to report

*Takeaway: Captured agencies now need the five foundations standing and a defensible record that the work has genuinely started.*

---

## Question 5: If you are not captured, can you prove it?

"We decided it does not apply to us" is not a compliance position. It is a risk - unless someone wrote down why.

If you conclude your business is out of scope, capture the reasoning the same way you would capture any other governance decision: which services you provide, why none of them is a brokering designated service, who made the call, and when. A one-page scoping memo is cheap. Reconstructing your thinking under regulator questions in 2027 is not.

This is the difference between a defensible "no" and a hopeful one. AUSTRAC has signalled it expects effort, not perfection, from businesses that genuinely engage - but a business that simply assumed it was exempt and kept no record has not engaged at all.

---

## Bottom line

The compass only has two readings. If you broker the sale, purchase or transfer of real estate, you are in - and the work ahead is a finite, well-defined list, not an open-ended panic. If you genuinely sit outside the designated service, you are out - but only if you can show your reasoning.

Either way, the worst position is the one most agencies are in right now: not actually knowing. With the services live on **1 July 2026** and enrolment due by **29 July 2026**, "we were not sure" stops being an answer very soon.

### Not sure which reading is yours?
Start with our plain-English AUSTRAC Tranche 2 guide, then map your agency's services against enrolment, program, screening and training in one place.

*   [Read the AUSTRAC guide](/Compliance/austrac-tranche-2-guide)
*   [Register for updates](/signup)

### Sources
*   [AUSTRAC - Real estate designated services](https://www.austrac.gov.au/new-austrac/designated-services-newly-regulated-entities/real-estate-designated-services) (Retrieved 14 June 2026)
*   [AUSTRAC - Check if you may be regulated](https://www.austrac.gov.au/amlctf-reform/check-if-you-may-be-regulated-reform) (Retrieved 14 June 2026)
*   [AUSTRAC - Summary of AML/CTF obligations for tranche 2 entities](https://www.austrac.gov.au/about-us/amlctf-reform/summary-amlctf-obligations-tranche-2-entities) (Retrieved 14 June 2026)
*   [AUSTRAC - Real estate program starter kit](https://www.austrac.gov.au/reforms/sector-specific-guidance/real-estate-guidance/real-estate-program-starter-kit/real-estate-program-starter-kit-getting-started) (Retrieved 14 June 2026)
*   [AUSTRAC - Enrol with us overview](https://www.austrac.gov.au/new-austrac/enrol-or-register/enrol-us) (Retrieved 14 June 2026)
*   [AUSTRAC - AML/CTF compliance officer](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/develop-your-amlctf-programs/step-1-establish-your-governance-framework/amlctf-compliance-officer) (Retrieved 14 June 2026)