⚡ Direct Answer: A reporting entity is a person or business that provides one or more “designated services” under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 with a geographical link to Australia. Reporting entities must enrol with AUSTRAC, maintain an AML/CTF program, conduct customer due diligence, monitor transactions, and submit required reports. From 1 July 2026, the definition of designated services is expanding significantly under the Tranche 2 reforms.
The Legal Definition of a Reporting Entity
Under the AML/CTF Act, a “reporting entity” is defined as a person who provides a designated service that has a geographical link to Australia. This definition encompasses both legal persons (companies, trusts) and natural persons (individuals and sole traders).
The geographical link requirement is satisfied in several ways — including where the service is provided from a permanent establishment in Australia, or where the customer is in Australia for certain types of services. The breadth of this definition means that some overseas businesses serving Australian customers may also be reporting entities.
Designated Services: The Complete Picture
The AML/CTF Act contains an exhaustive list of designated services. These are divided into two tables:
Table 1 — Financial Sector Services
- Accepting deposits and other repayable funds
- Providing credit, including consumer credit, mortgages, and overdrafts
- Issuing and managing payment instruments (including prepaid cards and digital wallets)
- Money or value transfer services
- Foreign currency exchange
- Issuing, selling, or redeeming traveller’s cheques and money orders
- Safe custody services
- Securities and derivatives services
- Superannuation and managed investment scheme services
- Insurance services (underwriting and distribution)
- Digital (virtual) currency exchange services
- Gambling services (casinos, wagering, gaming, lotteries)
- Pawnbroking services
Table 2 — Bullion Dealing
- Buying, selling, or otherwise dealing in bullion (physical gold, silver, platinum, or palladium)
New Designated Services from 1 July 2026
The Tranche 2 reforms introduce new designated services covering professional service providers. From 1 July 2026, the following services will be designated:
- Buying and selling real estate on behalf of clients (real estate agents)
- Managing client money, securities, or other assets (accountants, lawyers)
- Opening or managing accounts (accountants, lawyers, trust and company service providers)
- Organising contributions for creation, operation, or management of companies (corporate service providers)
- Creating, operating, or managing trusts or similar structures (trust service providers)
- Providing services as a nominee director, nominee shareholder, or company secretary
- New categories of virtual asset services
- Services related to precious metals, precious stones, and jewellery (for high-value dealers)
Full Obligations of Reporting Entities
Being a reporting entity brings a comprehensive set of legal obligations. These obligations apply from the moment you start providing designated services — not just after AUSTRAC registration or enrolment is complete.
1. Enrolment and Registration
All reporting entities must enrol with AUSTRAC within 28 days of commencing designated services. Remittance dealers and virtual asset service providers must also register. From 1 July 2026, newly regulated businesses must apply by 29 July 2026.
2. AML/CTF Program
Every reporting entity must develop and maintain a written AML/CTF program approved by a senior manager. The program must be in place before commencing designated services. It must be tailored to the nature, size, and complexity of the business and must be kept current as circumstances change.
3. ML/TF Risk Assessment
You must conduct an ML/TF risk assessment (including proliferation financing risk) that considers your customer types, services, delivery channels, and countries. The assessment must be documented and used to design your AML/CTF controls.
4. Customer Due Diligence
Reporting entities must conduct initial CDD on all customers before providing designated services. This includes identity verification, beneficial ownership identification, risk rating, PEP and sanctions screening. Ongoing CDD must be conducted throughout the relationship.
5. Transaction Monitoring
Customer transactions must be monitored on an ongoing basis to detect activity that is inconsistent with the customer’s known profile or otherwise suspicious.
6. Reporting Obligations
Reporting entities must submit Suspicious Matter Reports (SMRs), Threshold Transaction Reports (TTRs), International Funds Transfer Instructions (IFTIs), and Cross-Border Movement Reports (CBMRs) within required timeframes.
7. Record Keeping
Records of designated service transactions, CDD, and AML/CTF program documentation must be kept for a minimum of 7 years.
8. Employee Due Diligence and Training
Relevant employees must be subject to appropriate background checks and must receive AML/CTF training before commencing duties and on a periodic basis thereafter.
9. Independent Program Evaluation
Periodic independent evaluations of the AML/CTF program must be conducted to assess its effectiveness. Findings must be documented and implemented.
How to Confirm Your Reporting Entity Status
- List all services you currently provide (or plan to provide) to customers.
- Check whether any of these services appear in Table 1 or Table 2 of Part 1 of the AML/CTF Act, or in the new designated services from 1 July 2026.
- Confirm whether a geographical link to Australia exists for each service.
- If you determine you are a reporting entity, apply to enrol with AUSTRAC.
- If you are uncertain, seek advice from a qualified AML/CTF specialist — the consequences of incorrectly concluding you are not a reporting entity are significant.
Frequently Asked Questions
Can I check online whether my services are designated?
AUSTRAC’s website contains guidance on designated services and has tools to assist businesses in determining their status. However, the legislative provisions are the authoritative source — professional advice is recommended for complex situations.
What if I stopped providing a designated service?
If you cease providing all designated services, your reporting entity status ends. You should update your AUSTRAC enrolment to reflect this. However, your record-keeping obligations for past transactions continue for the applicable retention periods.
Are government agencies reporting entities?
Some government agencies that provide financial services (such as Australia Post’s financial services arm) may be reporting entities. However, many government functions are not covered by the AML/CTF Act. Specific advice should be sought for government entities.
📣 Need help with AML/CTF compliance?
👉 Check whether your business is a reporting entity: Do I need AML?
👉 Read the complete AML compliance guide: AML Compliance Australia – Complete Guide (2026)
👉 Get expert advice: contact us