Most Australian accountants are not ready for the AML/CTF Tranche 2 reforms due to take effect on 1 July, according to The Access Group. Its survey found only 6% felt on top of the legislation.
The poll of more than 1,700 accounting professionals across solo practitioners, small practices and mid-sized firms found 32% had not started engaging with the reforms, while 62% said they were unclear about the new rules. That was up from 50% a month earlier.
The findings highlight a compliance challenge for firms that will soon have to meet anti-money laundering and counter-terrorism financing obligations more commonly associated with banks and other regulated financial businesses. For accountants providing designated services, the changes will require written compliance programs, risk assessments, client due diligence checks, transaction monitoring, suspicious matter reporting procedures and staff training.
From 1 July, the reforms will bring about 80,000 new entities into the regime, joining around 15,000 businesses already covered. The Access Group described the shift for accounting practices as the most significant operational change since the introduction of GST.
Firms that have not enrolled with AUSTRAC are already behind. Non-enrolment carries a civil penalty of 60 penalty units a day for body corporates, equal to $18,780 a day under current indexation, while serious or wilful non-compliance can attract a maximum civil penalty of $31.3 million.
Readiness Gap
The issue is not simply a matter of preparing documents, The Access Group said. Firms providing designated services under the regime must have systems and trained staff in place before the deadline.
That includes appointing a designated AML/CTF compliance officer, setting up customer due diligence workflows for every client, creating a risk assessment framework across relevant services and establishing ongoing monitoring arrangements. Suspicious matter reporting procedures must also be in place, along with records showing staff have completed training.
The Access Group argued that available guidance does not give smaller accounting firms enough practical direction. While AUSTRAC has issued starter kits, factsheets and webinars, many accountants still lack step-by-step guidance tailored to how accounting practices operate, it said.
It also called on professional bodies including CPA Australia, Chartered Accountants ANZ and the IPA to provide more urgent, practical support for members. Firms need worked examples and service-specific guidance rather than broad compliance checklists, it said.
David Boyar, FCA, at The Access Group, said the profession was dealing with consecutive regulatory changes. "This is the latest in a cumulative burden on small practices, and the timeframe for compliance compounds an already significant challenge," Boyar said.
"The expanded TASA obligations - eight new Code of Professional Conduct requirements - only took full effect for most practices on 1 July 2025. Twelve months later, the same firms must stand up an entirely separate compliance regime.
"Two fundamental reforms to how accountants engage with clients, back-to-back. For small practices with no dedicated compliance resource, the operational pressure is acute. Paper-based processes and manual workflows are not a viable answer."
Operational Change
The reforms affect firms that provide designated services, meaning some accounting practices will need to review not only internal processes but also client onboarding and ongoing engagement procedures. For affected firms, identity verification and know-your-customer checks will need to become part of routine practice.
The Access Group said accountants should enrol with AUSTRAC if they have not already done so, appoint a compliance officer, commission or buy an AML/CTF risk assessment, start drafting a written AML/CTF program, audit their client base for designated service obligations and implement a client due diligence workflow before the deadline.
Boyar compared the situation to the introduction of GST, warning that delay would leave firms struggling once the rules came into force. "The firms that treated GST as a 'we'll figure it out' problem were the ones scrambling in August 2000. History is about to repeat for anyone not moving now," he said.
The Access Group is also promoting its compliance software for accountants, EngageAML, which it said was built specifically for Australian accounting practices. The product includes identity verification, biometric checks, politically exposed person and sanctions screening, automated risk assessment, transaction monitoring, support for drafting suspicious matter reports and record-keeping tools, according to the company.
It said the software integrates AML and know-your-customer checks into engagement workflows used by practices, allowing compliance tasks to sit within client onboarding rather than as a separate process. The company argued this could reduce the burden on small firms without dedicated compliance teams.
Boyar said technology would be central to how smaller firms meet the new rules. "The compliance officer role in a small firm only works if technology does most of the heavy lifting," he said. "Flagging risk, prompting reviews, maintaining records, generating reports - that is what the platform does. The partner makes the judgement calls."