Missed the AUSTRAC Enrolment Deadline?

If you have missed the AUSTRAC enrolment deadline (your business provides a designated service, the deadline to apply has passed, your name is not on AUSTRAC’s Reporting Entities Roll and you have not applied to enrol), you are in breach of section 51B of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and the breach grows every day. This assumes none of the exceptions in section 51B(2) and (2A) applies, such as an application you have already made for another designated service. The obligation does not lapse when the deadline passes: it continues until you apply, and each day from the deadline day until you apply is a separate contravention.

What to do first: submit a complete application to enrol, keep the submission receipt, designate your AML/CTF compliance officer if you have not, and respond separately to any notice you hold. Applying ends the continuing obligation; it does not erase contraventions already incurred.

AUSTRAC is enforcing it: on 30 September 2026 it announced that it had begun issuing infringement notices to real estate, accounting and jewellery businesses it believes failed to enrol. This guide explains the rule, what an infringement notice is, and how to apply late.

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TL;DR

The general rule is to apply to enrol no later than 28 days after you start providing a designated service. For a business that was already providing real estate designated services before 1 July 2026, and no other designated services at that time, the Amendment Act set the deadline at 29 July 2026.
After the deadline the obligation continues. Each day from the deadline day until the day you apply is a separate contravention. Applying stops new days accruing; it does not undo the days already passed.
Failing to enrol is a civil penalty provision and an infringement notice provision. The default infringement notice amount per alleged contravention is 60 penalty units for a body corporate and 12 for anyone else, which at $364 a unit is $21,840 and $4,368. These are amounts per alleged contravention in a notice AUSTRAC chooses to issue, not an automatic daily bill.
Paying an infringement notice within 28 days, or any longer period AUSTRAC allows, discharges the liability for the contraventions it covers, unless the notice is withdrawn.
Designating an AML/CTF compliance officer is a separate 28-day obligation with the same daily count (section 26K). For a business covered by the same 29 July transitional item, the notice to AUSTRAC of who it is is on time if given by the later of 29 July 2026 and 14 days after your name is entered on the Roll (Transitional Rules 2026, section 19).

The rule: when you had to apply
Why a missed deadline keeps growing
The compliance officer: a second deadline
What AUSTRAC has done in 2026
How an AUSTRAC infringement notice works
How to enrol with AUSTRAC after the deadline
After you enrol: the obligations enrolment does not cover
Our perspective
How AML Guard helps
FAQ
Sources

The rule: when you had to apply

Section 51B(1) of the Act says that if a person commences to provide a designated service and is not on the Reporting Entities Roll, the person must, no later than 28 days after the day on which they commence to provide the designated service, apply for enrolment as a reporting entity. AUSTRAC’s enrolment guidance puts it the same way: apply to enrol no later than 28 days after the day you start providing a designated service.

For real estate, the designated services are in table 5 of section 6 of the Act:

brokering the sale, purchase or transfer of real estate on behalf of a buyer, seller, transferee or transferor in the course of carrying on a business; and
selling or transferring real estate in the course of carrying on a business selling real estate, where the sale or transfer is not brokered by an independent real estate agent.

The obligations began on 1 July 2026. For businesses already in the market, the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 fixed the date. Under item 12 of Schedule 3, if a person provided a real estate designated service at any time before 1 July 2026 and did not, at that time, provide any other kind of designated service, section 51B(1) applies as if the 28 days were a reference to 29 July 2026. A business that started on or after 1 July 2026 has its own 28-day period, counted from its own start date. AUSTRAC’s guidance says a seller’s agent starts providing the designated service to the seller when the agreement to broker the sale is signed.

Two exceptions in section 51B can mean you had no separate deadline at all: where you have already applied to enrol in relation to another designated service and have not since asked to be removed from the Roll (section 51B(2)), or where you were already required to apply because of another designated service (section 51B(2A)).

Property management on its own is generally not a real estate designated service; our guide to AML/CTF and property management explains where the line sits.

Why a missed deadline keeps growing

The obligation continues. Under section 51B(2B), if you do not apply by the deadline, the obligation to apply continues until you apply or stop being a reporting entity, whichever comes first.
Each day is a separate contravention. Under section 51B(2C), you are taken to commit a separate contravention on each day on or after the day on which the enrolment deadline occurs, up to and including the day the obligation ends. Section 51B(2D) clarifies that there is no more than one contravention on any particular day.
It is a civil penalty provision. Section 51B(3). Under section 175, the maximum pecuniary penalty a court can order is 100,000 penalty units for a body corporate and 20,000 for other persons.

So applying stops the count; it does not erase the days between the deadline and your application. AUSTRAC then enters the business on the Roll under section 51D.

The compliance officer: a second deadline

Enrolment is not the only 28-day obligation. Under section 26K(1), a reporting entity that commences to provide a designated service must, no later than 28 days after that day, designate an individual as its AML/CTF compliance officer. AUSTRAC’s guidance says to appoint one within 28 days of providing designated services. The structure mirrors section 51B: the obligation continues until you designate someone or stop being a reporting entity (section 26K(3)), each day from the day of the deadline is a separate contravention (section 26K(4)), and it is a civil penalty provision (section 26K(6)). It is also a designated infringement notice provision (section 184(4)), carrying 60 penalty units for a body corporate and 12 for anyone else (section 186B).

If your business was already operating before 1 July 2026: section 26K has its own 28-day designation rule and its own daily count. The Amendment Act’s 29 July date is written for enrolment under section 51B; do not assume it moves the designation deadline. Section 26K sits in Part 1A of the Act, which the Amendment Act applied to real estate businesses from 1 July 2026 (Schedule 3, item 11), so when any past section 26K breach began depends on how those provisions apply to you. If none is designated, designate one now and take advice on past exposure.

Once you have designated your compliance officer, the general rule in section 26M(1) is to notify AUSTRAC of the individual within 14 days after the designation. For newly regulated businesses there is a transitional rule. Section 19 of the Anti-Money Laundering and Counter-Terrorism Financing Transitional Rules 2026 treats a business covered by item 12 of Schedule 3 to the Amendment Act as complying with section 26M(1) if it gives the notification by the later of 29 July 2026 and 14 days after the day its name is entered on the Reporting Entities Roll. AUSTRAC’s example: a business enrolled on 29 July 2026 had until 12 August 2026. If you applied late, check the date your business was entered on the Roll, and that item 12 covers you: section 19 of the Transitional Rules counts from Roll entry, not from the date you submitted the application.

What AUSTRAC has done in 2026

Date	What happened	Source
31 March 2026	Enrolment opened for the newly regulated sectors, including real estate professionals.	AUSTRAC media release, 31 March 2026
May 2026	AUSTRAC said it would take early enforcement action against businesses who fail to enrol.	AUSTRAC, 21 May 2026
28 August 2026	AUSTRAC said it had begun issuing section 167 notices to businesses that appear to provide designated services but have not enrolled.	AUSTRAC article, 28 August 2026
30 September 2026	AUSTRAC announced it had begun issuing infringement notices to real estate, accounting and jewellery businesses it believes failed to enrol within 28 days. It reported the notices as issued at $21,840 for corporate entities and $4,368 for individuals, and said around 90 per cent of a group it had concerns about had since enrolled or attempted to enrol.	AUSTRAC media release, 30 September 2026

The amounts in the last row are what AUSTRAC reported for the notices it issued, not a charge applied to every business that has not enrolled. AUSTRAC also said it is actively looking for businesses that haven’t enrolled and will issue more infringement notices where necessary. If you have received a section 167 notice, our guide to what to do with an AUSTRAC section 167 notice covers the response.

How an AUSTRAC infringement notice works

An infringement notice is an alternative to court. The rules are in Part 15, Division 3 of the Act.

Who can issue it, and when. An authorised officer, customs officer or police officer who has reasonable grounds to believe a person has contravened an infringement notice provision may give the person an infringement notice (section 184(1)). Failing to enrol under section 51B(1) is an infringement notice provision (section 184(1A)). For a designated infringement notice provision, such as the compliance officer obligations in sections 26K and 26M, only an authorised officer may give the notice (section 184(1B)). The notice must be given within 12 months after the day of the alleged contravention (section 184(2)).
How much. For section 51B(1), the penalty for each alleged contravention is 60 penalty units for a body corporate and 12 penalty units for any other person, unless the AML/CTF Rules specify a different number for a kind of contravention (section 186A). The Rules can set up to 120 and 24 penalty units respectively. AUSTRAC’s guidance gives the penalty unit value as $364 for contraventions on and from 1 July 2026, which is how 60 and 12 units become the $21,840 and $4,368 in AUSTRAC’s release.
More than one day, one notice. A single infringement notice may specify more than one alleged contravention (section 185(2)). Because each day without applying is a separate contravention, this is how the amount can grow. Whether AUSTRAC issues a notice, and for which days, are separate enforcement decisions.
Paying it. The notice must state that no criminal or civil penalty proceedings will be brought if the penalty is paid within 28 days, or any longer period AUSTRAC allows (section 185(1)(d)). If you pay and the notice is not withdrawn, your liability is discharged and criminal or section 175 proceedings may not be brought (section 188).
Withdrawal. A notice can be withdrawn within 28 days after it was given; a paid penalty is then refunded (section 187).
Not paying. If you do not comply with an infringement notice, the Act preserves the ability to bring civil penalty proceedings for the contravention (section 189). That is a possibility, not an automatic outcome.
Publicity. AUSTRAC’s guidance says infringement notices may be made public.

If you believe a notice is wrong, for example because you provide no designated service, take legal advice before the 28 days run out. Our guide to AUSTRAC penalties covers enforcement more broadly.

How to enrol with AUSTRAC after the deadline

Confirm whether you provide a designated service. Use AUSTRAC’s “Check if you may be regulated” tool and the real estate designated services guidance. If you broker property sales for clients in the course of business, you provide a table 5 designated service.
Apply through AUSTRAC Online. You need a user account first. AUSTRAC’s guidance says you can save your progress and return to the enrolment form for up to 14 days, and that after submitting you receive a confirmation with a receipt number and an AUSTRAC Account Number. Keep the receipt: the date you applied is the date the continuing obligation ended.
Designate your AML/CTF compliance officer and notify AUSTRAC. Section 26K sets its own 28-day rule. Work out your notification date from section 26M and, if the 29 July transitional item applies to you, section 19 of the Transitional Rules.
Call AUSTRAC if you are stuck. The AUSTRAC Contact Centre is on 1300 021 037. AUSTRAC has said contacting it for help isn’t a red flag.
Record the dates. Note when you started providing designated services, when you applied and when your name was entered on the Roll.
Respond to any notice you hold. A section 167 notice or an infringement notice has its own deadline. Applying to enrol does not answer either of them.
Take advice if you have been providing designated services for months without enrolling, or you hold a notice.

After you enrol: the obligations enrolment does not cover

An application is the step section 51B requires; AUSTRAC then enters the business on the Reporting Entities Roll under section 51D. Neither step, alone, satisfies the rest of your AML/CTF obligations. AUSTRAC’s May 2026 statement expects newly regulated businesses to be enrolled, to have an AML/CTF program and compliance officer, to train staff on the program, and to be ready to have a go at reporting when a suspicious matter arises.

Under the Act, that means a business-wide ML/TF risk assessment (section 26C), AML/CTF policies (section 26F) that you then follow (section 26G), a designated AML/CTF compliance officer (sections 26J and 26K), customer due diligence, generally before you provide a designated service (section 28), and suspicious matter reporting (section 41).

Enrolment brings its own obligations too: advising AUSTRAC of changes to your enrolment details of a kind specified in the Rules within 14 days (section 51F), and, while you remain on the Roll, obligations such as the annual compliance report.

Our perspective

AUSTRAC has made failure to enrol an enforcement priority. A prompt application and a documented remediation plan matter, but neither automatically cancels past exposure or a notice already issued.

Enrolment is not the finish line: the risk assessment, the policies and a trained team make the next customer file defensible.

How AML Guard helps

AML Guard is built for Australian Tranche 2 reporting entities. Its guided wizards produce your ML/TF risk assessment, AML/CTF program, customer acceptance policy and training manual, and can pre-fill later documents from your risk assessment. Customer due diligence, screening results and officer decisions are recorded against each case.

AML Guard is not self-service: firms start with a demo, where we look at your services and where you are up to.

FAQ

What happens if I missed the AUSTRAC enrolment deadline?

The obligation to enrol continues until you apply, and each day from the deadline day is a separate contravention of section 51B(1). AUSTRAC can issue an infringement notice or seek a civil penalty order in the Federal Court, and began issuing infringement notices in September 2026. Apply now to stop further days accruing, and check your compliance officer designation.

How much is the AUSTRAC fine for not enrolling?

An infringement notice carries 60 penalty units per alleged contravention for a body corporate and 12 for an individual, unless the Rules specify otherwise: $21,840 and $4,368 at $364 a unit. One notice can cover several days, so a total can be higher. These are not automatic daily charges, and a court-ordered civil penalty can be far larger.

Does enrolling late cancel the penalty?

No. Applying ends the continuing obligation, so no new contraventions accrue after the day you apply. The days from the deadline to your application remain contraventions under section 51B(2C), and any notice already issued still stands. A prompt application is still the most useful step you can take, because the count stops when you apply.

How long does AUSTRAC enrolment take?

AUSTRAC’s guidance says you need an AUSTRAC Online user account, then you complete the form to enrol a new business, which you can save and return to for up to 14 days. When you submit, you receive a confirmation with a receipt number and AUSTRAC Account Number, then a further email once you are enrolled.

I’m a property manager. Do I need to enrol?

Possibly not, if you only manage ordinary rentals. Property management is not a table 5 designated service, and managing rental income and expenses through a trust account is excluded from the professional services item that covers client money. If your agency also brokers sales, or handles other client money, it needs its own assessment. See our property management guide.

What if I enrolled but don’t actually provide a designated service?

AUSTRAC’s guidance says you should request removal from the Reporting Entities Roll through AUSTRAC Online. While you stay enrolled you keep obligations such as the annual compliance report, even in a year when you provide no designated services. Record why you concluded you provide none, in case AUSTRAC asks later.

Sources

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This article is for general information purposes only and does not constitute legal advice. Firms should obtain independent professional advice on their specific AML/CTF obligations.

Last reviewed: 26 October 2026.

Missed the AUSTRAC Enrolment Deadline? What Happens Next