The Tranche 2 compass: are you actually captured, and what do you owe by 1 July?

There are two ways an agency gets the next few weeks 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.

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)

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 go live 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)

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.

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