Key deadline
1 July 2026 — Tranche 2 reforms commence. All real estate agents become reporting entities. Enrolment with AUSTRAC required before this date.
From 1 July 2026, real estate agents become reporting entities under Tranche 2 of the AML/CTF Act and must verify the identity of every buyer and seller. Agents can conduct this check themselves, or rely on another reporting entity's check under a standing reliance arrangement (AML/CTF Act 2006, s.37A) — which is how Zettle's AML reliance service works for agents who refer clients to us.
From 1 July 2026, real estate agents are required to verify the identity of every buyer and seller under Australia's AML/CTF laws. This is part of "Tranche 2" of the reforms, which brings real estate agents into scope as reporting entities for the first time. Enrolment with AUSTRAC is required before that date.
1 July 2026 brings two separate regulatory obligations at the same time — most agencies are only aware of one of them.
Maximum penalty for corporations
Maximum penalty — most PI policies don't cover this
AUSTRAC requires
Privacy Act requires
A seller has a signed listing agreement with the agency, a pre-existing relationship, and commercial leverage — verification fits into an onboarding workflow that already exists. A buyer has no contract with the agency, may have been met at an open inspection or auction, has no obligation to cooperate, and there's a fixed deadline before settlement. Seller verification is manageable; buyer verification at scale, under time pressure, is a different challenge entirely.
Section 37A of the AML/CTF Act allows one reporting entity to rely on the identity verification conducted by another — known as a reliance arrangement. When an agent establishes a standing reliance arrangement with a conveyancer, the conveyancer conducts the CDD and the agent satisfies their obligation by relying on that check.
"A reporting entity may rely on a customer due diligence procedure carried out by a reliable third party in respect of a customer."
AML/CTF Act 2006, section 37A(1) · AML/CTF Rules 2025, section 6-29Banks have used the same mechanism since 2006. Under a standing reliance arrangement, the verification, record-keeping and AUSTRAC reporting obligations sit with the party conducting the check — not the relying agent. Section 37A(2) provides safe-harbour protection from AUSTRAC penalties for the relying party where that check is conducted properly.
When your clients use Zettle for conveyancing, we conduct full Customer Due Diligence — identity verification, PEP screening, beneficial ownership checks and source-of-funds assessment where required — as part of that process. Under a standing reliance arrangement between your agency and Zettle (structured under s.6-29 of the AML/CTF Rules 2025), you rely on our check to satisfy your obligation for those clients, at no cost to your agency.
For exactly how the setup and reliance workflow works, see how Zettle's AML reliance works, step by step.
The reliance arrangement covers CDD for clients who engage Zettle as their conveyancer. Your agency still needs to enrol with AUSTRAC and maintain its own AML/CTF program.
You can recommend Zettle to every client. For those who use a different conveyancer, you'll need to conduct your own AML checks or use a standalone verification service.
No. Zettle conducts AML checks as part of the conveyancing process. The agency pays nothing extra — not for the checks, not for the agreement.
Yes. The reliance arrangement covers every client referred to Zettle — buyers and sellers.
Agents need to enrol via the AUSTRAC portal before 1 July 2026.
Yes, when structured under section 6-29 of the AML/CTF Rules 2025 with the required elements — two-party execution, reassessment triggers and an immutable audit log.
For the buyer and seller side of this obligation, see our consumer-facing guide to the AML checks now applying to your property settlement.
Zettle is a solicitor-led, digital-first conveyancing service operating in QLD, NSW and VIC. This is general information about AML/CTF obligations, not legal advice for your agency's particular circumstances.
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