From 1 July 2026, new anti-money laundering and counter-terrorism financing (AML/CTF) rules for accounting clients apply to certain services provided by accountants and other professional advisers across Australia.

These reforms aim to reduce the risk of professional services being misused for money laundering, terrorism financing and other serious financial crime.

For accounting clients, the changes may mean some additional questions, identification checks and documentation when requesting particular services. However, not every accounting service is affected.

What are the AML/CTF rules for accounting clients?

AML/CTF laws require businesses that provide certain regulated services to understand who their clients are, assess potential risks, monitor relevant activity and report certain matters to AUSTRAC.

These regulated services are known as designated services.

What does this mean in simple terms?

Accounting firms must now complete additional checks when providing certain services.

Depending on the work requested, your accountant may need to:

• confirm or update your identity
• understand who owns or controls an entity
• confirm directors, shareholders, trustees or beneficial owners
• ask questions about a proposed transaction or change
• request identification or supporting documents
• complete further checks before beginning or continuing the service

The AML/CTF rules for accounting clients form part of Australian law. Therefore, individual accounting firms cannot choose whether to apply them.

Which accounting services are affected by the AML/CTF rules?

The requirements apply to the type of service being provided rather than every service performed by an accountant.

For example, standalone tax return preparation, bookkeeping and payroll services are generally not designated services.

However, the requirements may apply when an accountant assists with:

• buying, selling or transferring real estate
• buying, selling or transferring a company, trust, partnership or other legal arrangement
• receiving, holding, controlling or managing a client’s money or property to help carry out a transaction
• organising or assisting with equity or debt financing
• selling or transferring a shelf company
• creating or restructuring a company, trust, partnership or other legal arrangement
• acting, or arranging for someone to act, in certain company, trust or partnership positions
• acting, or arranging for someone to act, as a nominee shareholder
• providing a registered office or principal place of business address

Ultimately, whether the requirements apply will depend on the nature of the work and the circumstances surrounding the service.

What about company and trust establishments?

Helping establish a new company, trust, corporate trustee or other legal arrangement may qualify as a designated service.

As a result, your accountant may need to complete customer due diligence before proceeding with the establishment.

They may ask for:

• personal identification
• details of the proposed directors, shareholders or trustees
• information about the beneficial owners
• an explanation of the intended structure
• supporting company, trust or business documents

Your accountant may already hold some of this information. Even so, they may still need to confirm that it remains current or ask you to provide documents in a particular format.

What about ASIC changes?

Not every ASIC form or company update will automatically qualify as a designated service.

For instance, routine administrative work, such as receiving an annual company statement or updating basic contact details, may not trigger additional AML/CTF requirements.

However, the requirements may apply where an accountant plays a more active role in planning or carrying out:

• a company establishment
• a restructure
• a business or company sale
• a share transfer or change in ownership
• an equity financing arrangement
• the appointment of certain company, trust or partnership officeholders
• another change connected with a regulated transaction

Therefore, the accounting firm must assess the overall service rather than looking only at the ASIC form being lodged.

If the work requires further checks, documents or risk assessments, additional administration and fees may apply.

Do the AML/CTF rules apply to existing accounting clients?

Yes, they can.

The reforms do not apply only to new clients. They may also apply when an accounting firm provides a designated service to an existing or long-standing client.

However, this does not necessarily mean every client must complete an entirely new identification process each year.

Accounting firms have ongoing customer due diligence obligations. Therefore, they may need to review or update information when:

• contact or identification details have changed
• directors, shareholders or trustees have changed
• the ownership or control of an entity has changed
• the business or ownership structure has changed
• a designated service is requested
• previously supplied documents are no longer current
• further information is required based on the firm’s assessment of risk

For this reason, an accounting firm may use its annual engagement or client review process to confirm this information.

What are registered office services?

Every Australian company must have a registered office where it can receive official company correspondence and legal notices.

Some companies choose to use their accountant’s address as their registered office.

Providing a registered office or principal place of business address now qualifies as a designated service. Consequently, the accounting firm may need to carry out additional customer due diligence, monitoring, administration and record-keeping.

The firm may also charge an additional annual fee to cover the work involved.

It is also important to understand that being a company’s ASIC registered agent differs from being its registered office.

An accountant may remain appointed as the ASIC registered agent and continue assisting with annual company statements, ASIC correspondence and company updates even if the company uses a different registered office address.

Will the new AML/CTF rules result in additional fees?

The expanded requirements create additional obligations for accounting firms, including:

• customer due diligence
• risk assessments
• ongoing monitoring
• additional documentation
• record-keeping
• compliance reviews

As a result, an additional fee may apply where a service requires extra AML/CTF work.

The amount will depend on the type of service, the complexity of the client or structure and the level of checking required. Your accountant should explain any additional fee before proceeding with the service.

What should you do next?

For most clients, routine services such as tax returns, bookkeeping and payroll will continue as usual.

However, if you request a designated service, your accountant may need to ask additional questions, confirm your information or request identification and supporting documents.

These requirements may also result in additional fees where the service involves more administration, due diligence or ongoing compliance work.

If you are unsure whether the new AML/CTF rules may affect a service you need, speak with your accountant before proceeding.