Reporting Entity

Industry:
Table of Contents

Summary & Highlights of Rreporting Entity

  • Meaning: A reporting entity is an entity that provides any designated services listed under section 6 of the AML and CTF Act.
  • Why it matters for Tranche 2: From 1 July 2026, new designated services typically provided by real estate professionals, conveyancers, dealers in precious metals stones and products, lawyers, accountants, and TCSPs will come under regulation as Tranche 2 entities.
  • What it triggers: Once you are a reporting entity, you must meet obligations under the AML and CTF Act. AUSTRAC+1

What is a Reporting Entity? Definition & Legal Meaning

AUSTRAC defines a reporting entity as an entity that provides any designated services listed under section 6 of the AML and CTF Act. AUSTRAC also notes that, from 1 July 2026, new designated services will come under regulation that are typically provided by Tranche 2 sectors such as real estate professionals, conveyancers, dealers in precious metals stones and products, lawyers, accountants, and trust and company service providers, and that additional virtual asset related services will come under AML and CTF regulation from 31 March 2026.

AUSTRAC’s glossary also defines a designated service as a service listed in section 6 of the Act that meets the geographical link.

Real-World Examples

  • A conveyancing business providing a regulated designated service becomes a reporting entity once the Tranche 2 obligations commence.
  • A TCSP providing company formation and related designated services becomes a reporting entity for those services.
  • A business providing virtual asset related services that come into scope from 31 March 2026 is treated as a reporting entity for those services.

Best Practices for Tranche 2 Readiness

  • Start with a designated service assessment so you know which parts of your business will be regulated.
  • Build an implementation plan that covers governance, customer due diligence, ongoing monitoring, staff training, and suspicious matter reporting readiness before the start date.
  • Keep a clear boundary between regulated and non regulated workstreams where your business offers both.

Common Challenges

  • Assuming you are regulated because you are in a listed Tranche 2 sector, without confirming whether you actually provide a designated service.
  • Treating compliance as a single policy document rather than an operating model.
  • Leaving enrolment and system setup too late, which creates operational disruption close to go live.

Conclusion & Compliance Checklist

Reporting entity is the key gateway term. If you provide a designated service with the geographical link, you are in scope, and you must comply. Tranche 2 success comes from confirming scope early and building a practical compliance operating model, not from last minute paperwork.

How Tranche 2 Consultants can help: We can confirm your designated services, build your AML and CTF program and procedures, design KYC and ongoing monitoring workflows, and run implementation training so you are ready for the 2026 start dates.

“Bookmakers sit at a natural convergence point for cash, speed and anonymity. AUSTRAC’s focus reflects the reality that wagering platforms can be misused as value transfer mechanisms if risk controls are not actively applied.”

Reporting Entity FAQs

Are all real estate agents automatically reporting entities?
Only if they provide a designated service that is listed under section 6 and meets the geographical link. The sector label alone is not enough.
 
When do Tranche 2 businesses become reporting entities?
AUSTRAC states that, from 1 July 2026, new designated services typically provided by Tranche 2 sectors come under regulation.
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