Yes, but only when they provide a designated service. From 1 July 2026 an accounting practice that provides any Table 6 designated service, such as assisting a client to buy or sell a business or to create or restructure a company or trust, becomes a reporting entity under AUSTRAC and the AML/CTF Act 2006. Enrolment with AUSTRAC has been open since 31 March 2026, and in-scope firms must operate a documented AML/CTF program from 1 July 2026.

The designated services for accountants are the same Table 6 items (1 to 9) that apply to lawyers, and they capture transactional and structural work rather than general accounting. In scope: assisting a client to buy, sell or transfer a business (item 1) or company shares (item 2), holding or managing client money in connection with a transaction (item 3), arranging equity or debt financing (item 4), selling a shelf company (item 5), creating or restructuring a company, trust or partnership (item 6), and providing director, nominee or registered office services (items 7 to 9).

No. Preparing tax returns (including GST, BAS and FBT), conducting financial statement audits, general bookkeeping and management accounting, and ongoing SMSF administration are not designated services under the AML/CTF Act. These activities are general compliance and assurance work, not the transactional or structural services Table 6 targets. The exception is where the same engagement also involves a Table 6 activity, in which case that specific transactional component is in scope.

Yes. Assisting a client to plan or execute the creation or restructuring of a company, trust or partnership is a designated service under item 6 of Table 6, so it triggers AML/CTF obligations. This includes converting a sole trader to a company, restructuring a corporate group, creating a new trust, and selling or transferring a shelf company (item 5). Establishing an SMSF can also be in scope where it involves creating a trust or corporate trustee, even though ongoing SMSF administration is not.

Initial customer due diligence (CDD) must be completed before or at the time the accountant commences providing the designated service, not when the client relationship first begins. The trigger is the specific designated service, so even a client whose tax returns you have prepared for twenty years must be CDD'd before you start assisting with, for example, the sale of their business. Familiarity with a client does not remove the obligation to conduct and document CDD.

A. For an individual client, collect and verify full legal name, date of birth and residential address, then run PEP and sanctions screening, record the nature and purpose of the engagement, and assign a risk rating. For a company, collect the legal name, ACN or ABN and registered office, verify the entity through ASIC, and identify the ultimate beneficial owners (any natural person owning or controlling 25% or more, or the senior managing official if no one meets the threshold). For a trust or SMSF, identify and verify the trustee(s), settlor and beneficiaries or class of beneficiaries, and check the trust deed.