There’s a lot of noise in the industry right now about AML/CTF Tranche 2. We’re hearing it, and we know members of sectors impacted by Tranche 2 are certainly hearing it. We’ve seen various marketing campaigns urging immediate action, and it’s easy to feel overwhelmed (or worse, misled) by the messages. We want to be really clear, though – this isn’t the time for panic. It’s time for clarity. Use the lead-up to the 2026 deadline as your runway to fully understand your obligations.
The fact is that the AML/CTF Tranche 2 laws are still being finalised, and specific guidance has yet to be released. No business can yet be fully compliant with the upcoming reforms. So if you’re feeling pressured to buy a program, start your risk assessments, or onboard a solution today, this is your reminder that you still have plenty of time.
“The rules aren’t finalised yet”
AUSTRAC CEO Brendan Thomas put it best to attendees at the #ACCELERATERegTechGlobal conference in Sydney last month. He said, “The rules aren’t finalised yet and the guidance isn’t out so it’s impossible to design a solution that fully meets Tranche 2 obligations at this stage.”
This is a critical reminder to industry professionals across conveyancing, law, real estate, accounting, and other related fields not to be pressured into solutions that promise Tranche 2 compliance today. The facts simply don’t support those claims.
What do we know is true right now?
As of June 2025, here are the facts that we can confirm about the AML/CTF Tranche 2 rollout:
- AUSTRAC is still working with industry to finalise the specific rules (in fact, the second consultation phase is currently open, with feedback invited by 27 June 2025)
- Industry-specific guidance material and starter packs are expected to start rolling out by AUSTRAC from December 2025
- For businesses impacted by Tranche 2 regulations, you cannot even enrol with AUSTRAC until 2026
- You cannot create compliant risk assessments or AML/CTF programs for Tranche 2 industries yet
- 1 July 2026 is the current go-live date. None of your obligations come into effect until then.
In other words, you don’t need to be AML/CTF-compliant right now. But you do need to start preparing.
What’s causing the panic?
There’s been a surge of fear-based marketing and misinformation around Tranche 2. Some solution providers are promising “Tranche 2-compliant programs” or encouraging businesses to onboard immediately. This simply isn’t possible, and it risks wasting your time, money, and energy if you do only to find out that it’s not quite suitable closer to the implementation date in 2026.
Brendan Thomas has highlighted these incorrect claims by saying, “Some of the compliance issues we’re seeing involve the use of regtech; for instance, when businesses set up a system that is not appropriately tuned into the specific risks or types of suspicious behaviour we expect to see in that business model.”.
It’s frustrating to see such a significant regulatory change being hijacked with misleading claims. The stakes are too high, and businesses deserve clarity, not confusion.
What will be required by 1 July 2026?
Here’s what we know you’ll need to have in place once Tranche 2 goes live on 1 July 2026:
- Be Enrolled with AUSTRAC
- Have completed a compliant Risk Assessment
- Have developed an AML/CTF Program (and maintain this)
- Have trained your team on the program and reporting obligations
- Be ready to report suspicious matters if/when required
These are not small tasks, but they’re not due today. You have over a year to prepare properly, with the proper guidance.
What should you do now?
Now is the time to start learning. Here’s what we recommend:
- Stay informed via trusted sources, including AUSTRAC and your industry bodies (like AIC, REIA, Law Council of Australia, and the Tax Practitioners Board)
- Start exploring your options for digital ID and KYC support, but don’t lock in a program just because it claims it’s already “Tranche 2-compliant”
- Understand your likely obligations and consider how you’ll meet them. This may be internally or with a trusted partner. Some excellent information is available on AUSTRAC’s website.
- Set a calendar reminder for December 2025, when AUSTRAC is planning to release starter packs and official industry-specific guidance. You can also register for email updates from AUSTRAC as they become available.
Scantek is here to help, not hype.
At Scantek, we’re not here to sell you fear. We’re here to keep you informed and prepared, so that when July 2026 comes around, you’re ready to go.
As one of Australia’s leading digital ID verification providers, we already work with AML/CTF-regulated industries across gaming and finance. That means we understand the regulatory environment, and we know how to build smart, secure solutions that make compliance simple.
We’re closely following every update from AUSTRAC and will be adapting our technology to support Tranche 2 customers as new requirements are released. If you choose to work with us, you’ll have peace of mind that your tools will evolve alongside the rules.
Where to now with AML/CTF Tranche 2?
Hearing a lot of noise? Feeling confused? We’re here to provide you with nothing but the facts, so that you feel empowered to take your time and not rush into anything. Use the next six months to understand the landscape, learn from trusted sources, and connect with providers who will walk with you through the changes (and not push you before you’re ready).
Want to keep up to date with the latest AML/CTF Tranche 2 developments? Join our easyAML Readiness List to ensure you’re the first to know about AML/CTF updates!