AUSTRAC enrolment is now open. 

For real estate agencies, that marks a shift. The AML reforms have moved from something on the horizon to something that is actively in play. 

We are now in the window between enrolment opening on 31st March and obligations beginning on 1st July. What happens in this period will determine whether agencies are prepared, or under pressure. 

This is not about rushing to complete everything immediately. It is about understanding what needs to be built, who owns it, and how it will work in practice. 

The key dates to work towards 

The current phase, April through May, is your working window. This is when agencies should be building their approach and starting to put structure in place. 

From 1 July 2026, AML obligations formally begin for real estate. At that point, agencies are expected to be operating under the framework, not just preparing for it. 

If your business is operating from 1 July, you then have 28 days to complete enrolment, which places the practical deadline at 29 July 2026. 

What agencies should be doing now 

The focus now should be on progress, not perfection. 

The first step is clarity. Agencies need to understand whether they are likely to be regulated and what services they provide that fall within scope. For most businesses involved in property transactions, the answer will be straightforward. 

From there, responsibility needs to be defined. AML cannot sit in the background or be treated as a shared task. In most agencies, this will sit with the Licensee in Charge, a principal, or a senior operations lead. Without clear ownership, implementation tends to stall. 

Once responsibility is established, the next step is to begin building the framework itself. This does not need to be fully formed at this stage, but it does need direction. Agencies should be thinking about how they identify customers, how they assess risk, how processes will be documented, and how responsibilities will sit across the team. 

Most agencies will find that elements of this already exist in some form. Customer identification, onboarding and general due diligence are not new concepts. What AML requires is that these processes become structured, consistent and documented. This is where the shift from informal practice to formal compliance begins. 

What needs to be in place before 1 July 

By the time obligations commence, agencies should not be starting from zero. 

They should have a working framework in place, even if it continues to evolve over time. This includes a defined AML/CTF program, clear internal responsibility, documented customer due diligence processes, and a basic level of staff awareness. 

The goal at this stage is not legal perfection. It is operational readiness. Agencies should be in a position where their processes can actually be used in day-to-day work. 

What must be completed by 29 July 

For agencies operating from 1 July, enrolment must be completed within 28 days. 

By 29 July 2026, businesses should have finalised their AUSTRAC enrolment, confirmed the services they provide, and established the governance and record-keeping required under the framework. 

Importantly, this is not just an administrative step. By this point, agencies should already be operating under their AML processes, not implementing them for the first time. 

 Where agencies tend to get caught out 

The main risk is not misunderstanding the legislation. It is timing. 

A common pattern is treating July as the starting point, rather than the point where expectations shift. Without early ownership and structure, agencies can find themselves trying to build processes quickly in June, often under unnecessary pressure. 

AML is not a one-week implementation. It requires decisions, structure and internal alignment. 

What this means in practice 

These changes will not sit in isolation. 

AML will flow through core parts of the business, including onboarding, customer checks, internal accountability, staff awareness and escalation of unusual situations. Over time, it becomes part of how an agency operates. 

Handled early and practically, it integrates into existing workflows. Left too late, it creates disruption. 

 How Under The Hammer is supporting agencies 

At Under The Hammer, we work with real estate agencies implementing compliance in practice. 

As the AML reforms progress, our focus is on helping agencies move from understanding to execution — and building processes that actually work in a real business. 

Our aim is simple: help agencies build compliance they can rely on. 

This article provides general information only and should not be relied on as legal advice. All key dates referenced are based on AUSTRAC’s official guidance and published timelines.