Key deadline

1 July 2026 — Tranche 2 reforms commence. All real estate agents become reporting entities. Enrolment with AUSTRAC required before this date.

On this page

The obligation from 1 July Why it's hard for agents Our solution How Zettle's AML reliance works Get started Common questions
Referral partner overview Zettle AML Reliance · Real Estate Agents · From 1 July 2026

We do the AML check for every client you refer. For FREE.

From 1 July, real estate agents must verify every buyer and seller. When your clients use Zettle for conveyancing, we handle it — at no cost to your agency. Here's how it works and what you need to know.

The obligation

From 1 July, agents must verify every client. Zettle does it for the ones you refer.

From 1 July 2026, real estate agents are required to verify the identity of every buyer and seller under Australia's new AML/CTF laws. When your clients use Zettle for conveyancing, we conduct that verification as part of our process — at no cost to you or your clients. Sign one agreement with Zettle and every client you refer is covered, buyers and sellers.

Two regulators. One deadline.

1 July 2026 brings two separate regulatory obligations at the same time. Most agencies only know about one of them.

AUSTRAC · AML/CTF Act

Identity verification for every buyer and seller

Verify identity — name, DOB, address, primary ID
Screen for PEPs and sanctions
Risk-rate the client and document the assessment
Retain records for 7 years

Penalties up to $33M for corporates

OAIC · Privacy Act

The regulator most agencies aren't aware of

Privacy Act now applies to every reporting entity
APP-compliant privacy policy required on every client
Cannot store driver's licences in matter files
Notifiable Data Breaches plan required

Penalties up to $50M. Most PI policies don't cover privacy breaches.

AUSTRAC penalty

$33M

Maximum penalty for corporations under the AML/CTF Act

Privacy Act penalty

$50M

Maximum penalty under the Privacy Act — most PI policies don't cover this

The challenge for agents

The buyer isn't your client. You're being asked to verify them anyway.

Your vendor has a listing agreement with you. You know them. You have leverage to gather documents. But the buyer? They met you at an open inspection. No contract, no relationship, and now you need their full identity before settlement.

That's the operational problem Tranche 2 creates for agents. Seller verification is manageable. Buyer verification — at scale, under time pressure — is a different challenge entirely.

Buyers vs sellers — the operational reality

The buyer isn't your client. You have no contract with them, no leverage, and a deadline.

Seller — manageable

Your vendor is your client

Signed listing agreement
Pre-existing relationship
Commercial leverage to gather documents
Onboarding workflow already exists
Buyer — the problem

The buyer has no obligation to you

No contract with your agency
Met at auction or open inspection
No leverage to chase documents
Tight deadline before settlement
Our solution

You have a problem. We solve it.

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 6-29

When your clients use Zettle for conveyancing, we conduct full Customer Due Diligence as part of that process. Under a standing reliance arrangement between your agency and Zettle, you rely on our check to satisfy your AML obligation for those clients. The verification, record-keeping and AUSTRAC reporting obligations fall on us — not you.

Banks have used the same mechanism since 2006.

What Zettle's reliance covers

One agreement — Standing reliance under s.6-29. Sign once. Covers every buyer and seller who uses Zettle.
Free — We run AML checks as part of conveyancing. Your agency pays nothing extra.
Smaller privacy footprint — Zettle holds the client's personal information. No driver's licences on your systems.
Safe harbour — Section 37A(2) protection from AUSTRAC penalties where Zettle conducts the check. Your liability is capped.

What changes for your agency — before and after

Task Without reliance With Zettle reliance
Chasing clients for IDYour team does itZettle does it
PEP & sanctions screeningYour platform, your subscriptionDone by Zettle
Storing client records 7 yearsOn your systemsOn Zettle's systems
Privacy Act exposureFull APP burdenCollapsed to metadata only
AUSTRAC liabilityFullSafe harbour under s.37A(2)
Cost to your agencySoftware fees + staff timeZero
How Zettle's AML reliance works

How Zettle's AML reliance works

The entire AML workflow runs automatically once your reliance arrangement is in place. Your agency reviews a verified package and acknowledges it — that's the job.

One-time setup

Sign the reliance agreement

A standing reliance agreement between your agency and Zettle, set up via Livesign. Done once, covers every future transaction.

Per transaction

Client engages Zettle for conveyancing

Your client chooses or is referred to Zettle as their conveyancer. Recommend us on every transaction.

Zettle

Zettle conducts full CDD

Identity verification, PEP screening, beneficial ownership checks and source of funds assessment where required. All handled by Zettle.

Automatic

Verified package delivered

The verified KYC package is delivered to your AML system automatically. No manual handoff.

Your agency

Review and acknowledge

Your team reviews the verified package, forms their own risk view and acknowledges. Minutes, not hours.

Get started

Three steps. Done in under 10 minutes.

Setting up your AML reliance with Zettle is straightforward. Here's what the process looks like from start to finish.

1

Sign up to the Zettle referral portal

Create your account at refer.zettle.com.au. Takes about 1 minute — no contract, no subscription, no setup cost.

2

Connect your agency to Zettle via Livesign

Inside the portal, go to Admin → AML Reliance. One click opens Livesign, where you link your agency to Zettle. This allows compliance data to be shared securely between your agency and Zettle.

3

Review and sign the reliance agreement

In your Livesign dashboard, Zettle's reliance agreement will be waiting. Review and countersign — this activates the arrangement. Every client you refer to Zettle has their AML check handled by us, automatically.

That's it. No per-client paperwork, no ongoing cost. Your reliance arrangement covers every buyer and seller you refer to Zettle from that point forward.

Get started — join the referral portal

Free to join · No contract · Start referring immediately

Common questions

What agencies ask us most

Does this cover all my AML obligations?

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. We'll walk you through what that involves.

What if the client doesn't use Zettle?

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 service.

Is there a cost to our agency?

No. Zettle conducts AML checks as part of the conveyancing process. Your agency pays nothing extra — not for the checks, not for the agreement.

Does this cover sellers as well as buyers?

Yes. The reliance arrangement covers every client you refer to Zettle — buyers and sellers.

How do I enrol with AUSTRAC?

You'll need to enrol via the AUSTRAC portal before 1 July 2026. Book a call with our team and we'll walk through exactly what's required.

Is the standing agreement AUSTRAC-compliant?

Yes. The arrangement is structured under s.6-29 of the AML/CTF Rules 2025, executed via Livesign with all required elements — two-party execution, reassessment triggers and an immutable audit log.

Ready to sort your AML?

Become a referral partner and every client you refer to Zettle has their AML check handled — free, with no action needed per matter.

Become a referral partner