If your business provides designated trust and company services from 1 July 2026, you must enrol with AUSTRAC. This applies because trust and company service providers are newly brought into the federal AML/CTF regime where they help set up, manage or support structures that can be misused to hide ownership or move illicit funds. If you miss enrolment, you will be in breach of the Act, and civil penalties can reach $33.5 million per contravention, with criminal penalties for intentional contraventions.
Your AML/CTF obligations
AUSTRAC enrolment is the first legal step for a trust and company service provider that is a reporting entity. It is not a licence and it is not approval from AUSTRAC to operate. It is a mandatory notification to AUSTRAC that your business provides a designated service. For this sector, the key issue is whether the service you provide is actually a designated service under the Act, not whether you describe yourself as a corporate services firm, family office support business, accounting practice or legal-adjacent provider.
Deadline you cannot miss
If you are already operating and will provide a designated service from 1 July 2026, enrol with AUSTRAC by 29 July 2026 using AUSTRAC Online at austrac.gov.au. If your business starts providing a designated service after 1 July 2026, you must enrol within 28 days of first providing that service. Enrolment is free.
What a trust and company service provider should do now
The most common mistake in this sector is assuming enrolment only applies to businesses that call themselves a 'trust and company service provider'. AUSTRAC regulates designated services, not job titles. Another common error is thinking enrolment can wait until your AML/CTF program is finished. It cannot. Enrolment comes first, and your AML/CTF program must be finalised by 31 December 2026. Some firms also miss the point that a separate business entity may need its own enrolment if it is the one contracting with clients and providing the designated service.
For small corporate secretarial and trustee services businesses, the practical approach is to map your services client by client. If you help establish companies, arrange nominee or trustee structures, provide registered office or business address services as part of a broader designated service, or otherwise support legal entities in a way captured by the Act, check that activity carefully. Keep a dated internal note of why you concluded a service is or is not designated, who made that decision, and which entity in your group enrolled. That will make later compliance work much easier and help avoid gaps if you operate across several brands or related entities.
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