Tranche 2 AML/CTF Reforms: What bookkeepers need to know

You may have heard rumblings about upcoming anti-money laundering reforms under ‘Tranche 2’. Or perhaps, this is a term you’re encountering for the first time reading this article. Either way, there’s a lot of noise out there in the wider financial services industry, and it can be hard to know what’s relevant to your work as a bookkeeper.

Let’s start with the good news: the national ‘Tranche 2’ changes coming into effect from 1 July 2026 will not directly impact bookkeepers. But before you tune out entirely, you might like to read the rest of this article….

What is Tranche 2?

Tranche 2 refers to long-awaited reforms to Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime. These reforms aim to bring more professions under the scope of AML/CTF regulation, closing gaps that currently leave room for financial crimes to be committed.

Under Tranche 2, a broader range of Designated Service Providers will be required to:

  • Enrol with AUSTRAC (Australia’s financial intelligence agency)
  • Verify the identities of clients
  • Establish and maintain an AML/CTF compliance program
  • Train staff and keep relevant records
  • Report suspicious activity via Suspicious Matter Reports (SMRs)

Who is impacted by the AML/CTF changes?

From 1 July 2026, lawyers, conveyancers, accountants, and real estate professionals offering designated services will be required to comply with the AML/CTF Act.

However, bookkeepers are not currently included in these changes.

That said, some of your clients or partners, particularly tax agents who offer broader advisory services, may be impacted. So, even though you’re not directly affected, it’s important to understand the changes to help guide and support the businesses you work with and for.

What do these changes mean?

AUSTRAC is still in the process of finalising the rules and industry guidance, with more information, including starter compliance programs expected by December 2025. This means no business can currently create a compliant AML/CTF program or risk assessment (and no one should be locking into solutions based on incomplete information).

Now is the time to educate yourself, and get clear on your obligations. Now is not the time for panic.

AUSTRAC CEO Brendan Thomas recently emphasised this in a statement:

“We do not expect newly regulated businesses to be perfect at identifying and controlling for money laundering risks from day one. We do expect honest efforts to meet your obligations and report suspicions to AUSTRAC.”

How Scantek is supporting ICB members

As an approved VOI provider for the Institute of Certified Bookkeepers, Scantek is closely monitoring the evolving regulatory landscape. While bookkeepers are not required to meet AML/CTF compliance obligations at this stage, we’re committed to keeping you informed and ready in case things change in future.

Whether you’re a BAS agent verifying client identity for your own records or working alongside accountants or tax agents preparing for Tranche 2, our platform helps you complete secure, fully digital VOI in minutes.

There’s no app to download, no clunky back-and-forth, just a smooth experience for both you and your clients.

New, simplified pricing for VOI

We’ve also listened to your feedback and updated our pricing structure. You no longer need to purchase VOI in bulk to get started. Just pay per verification as needed.

It’s now easier than ever to add a secure identity check to your workflow.

Looking ahead to Tranche 2 and beyond

Tranche 2 reforms represent a significant shift in Australia’s financial crime landscape. Even if you’re not directly affected, understanding the broader picture will help you better support your clients, and prepare in case the scope expands down the track.

At Scantek, we’re here to help you stay informed, compliant, and confident. We’ll continue working with ICB to ensure you have the tools, guidance, and updates you need, now and into the future.

Want to learn more about Scantek’s VOI solution for bookkeepers and BAS agents?

Visit scantek.com for more information.

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