--- title: "Key Dates for Tranche 2 Compliance | HeadStart Docs Blog" description: "Important milestones for businesses preparing for AML/CTF Tranche 2 compliance, including enrolment and commencement dates." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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We provide digital products for AML/CTF compliance, not legal services." } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Shop", "item": "https://www.headstartdocs.com.au/shop" }, { "@type": "ListItem", "position": 3, "name": "Tranche 2 Hub", "item": "https://www.headstartdocs.com.au/tranche-2" }, { "@type": "ListItem", "position": 4, "name": "Sanctions Search", "item": "https://www.headstartdocs.com.au/sanctions-search" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "Do I still need a solicitor for AML/CTF Tranche 2 compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation." } }, { "@type": "Question", "name": "How is HeadStart Docs different from the free AUSTRAC Starter Kits?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools." } }, { "@type": "Question", "name": "What if the AML/CTF rules change after I purchase?", "acceptedAnswer": { "@type": "Answer", "text": "Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists." } }, { "@type": "Question", "name": "What happens after my 12-month AML portal access expires?", "acceptedAnswer": { "@type": "Answer", "text": "Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required." } }, { "@type": "Question", "name": "Is HeadStart Docs a law firm?", "acceptedAnswer": { "@type": "Answer", "text": "No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel." } }, { "@type": "Question", "name": "When does AML/CTF Tranche 2 commence in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date." } } ] }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Free Resources", "item": "https://www.headstartdocs.com.au/tranche-2-resources" }, { "@type": "ListItem", "position": 3, "name": "Key Dates for Tranche 2", "item": "https://www.headstartdocs.com.au/tranche-2-resources/key-dates-tranche-2" } ] }, { "@context": "https://schema.org", "@type": "Article", "headline": "Key Dates for Tranche 2 Compliance", "description": "Important milestones for businesses preparing for AML/CTF Tranche 2 compliance, including enrolment and commencement dates.", "datePublished": "2025-12-09", "dateModified": "2025-12-09", "url": "https://www.headstartdocs.com.au/tranche-2-resources/key-dates-tranche-2", "image": "https://www.headstartdocs.com.au/logo-512.png", "inLanguage": "en-AU", "isPartOf": { "@type": "WebSite", "name": "HeadStart Docs", "url": "https://www.headstartdocs.com.au" }, "about": { "@type": "Thing", "name": "AML/CTF Compliance", "description": "Anti-Money Laundering and Counter-Terrorism Financing compliance for Australian businesses under Tranche 2" }, "author": { "@type": "Organization", "name": "HeadStart Docs" }, "publisher": { "@type": "Organization", "name": "HeadStart Docs", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png" } } } ] --- [Get Started ](/checkout) We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) ![Key dates for Tranche 2 compliance](/assets/sydney-2026-CXTXtcf9.jpg) [Back to Free Resources](/tranche-2-resources) 1 December 2025 • Planning # Key dates for Tranche 2 compliance: Timeline and deadlines Understanding the critical dates and milestones for AML/CTF Tranche 2 implementation is essential for timely compliance. Here's your comprehensive timeline. ### Critical Alert Tranche 2 entities come under AUSTRAC regulation from 1 July 2026. Enrolment opens 31 March 2026 and cannot be done earlier. Ensure your AML/CTF program is in place before providing any designated services. Non-compliance may result in significant penalties. ## Complete Timeline 31 Mar 2026 Enrolment Opens ### AUSTRAC Enrolment Portal Opens The AUSTRAC online enrolment system becomes available for reporting entities to register. Note: enrolment cannot be done earlier than this date. **What to prepare:** - Business ABN and ACN (if applicable) - Details of compliance officer - Business contact information - List of designated services you'll provide 1 Jul 2026 Obligations Apply ### Tranche 2 Obligations Apply All AML/CTF Tranche 2 obligations apply from this date. Businesses providing designated services must be enrolled with AUSTRAC and comply with all requirements including customer due diligence, record keeping and reporting obligations. **Must be complete by this date:** - AUSTRAC enrolment finalised - AML/CTF program written and adopted - Compliance officer appointed - Staff training completed - Customer due diligence procedures implemented - Record keeping systems in place By 30 Jun 2029 First Review ### First Independent Evaluation Due Under Rule 5-10, reporting entities must have their AML/CTF program independently evaluated at intervals not exceeding 3 years. The first evaluation is due by 30 June 2029 (3 years from commencement). An earlier review may be required if there is an adverse finding, AUSTRAC issues a direction, or there is a material change in your circumstances. **Review requirements:** - Must be conducted by someone independent of day-to-day operations - Should assess compliance with all program requirements - Must result in a written report - Board or senior management should review findings ## Preparation Timeline To ensure smooth compliance, many professionals follow a preparation schedule similar to this: Now - Dec 2025 **Education & Planning Phase** - Understand which services are in scope - Conduct preliminary risk assessment - Review current client identification processes - Budget for compliance costs - Identify or recruit compliance officer Jan - Feb 2026 **Documentation Phase** - Draft your AML/CTF program documentation - Develop customer due diligence procedures - Create suspicious matter reporting workflows - Establish record keeping systems - Prepare staff training materials Mar 2026 **Implementation Phase** - Finalise AML/CTF program documentation - Have solicitor review and customise documents - Board/partners approve program - Complete AUSTRAC enrolment - Conduct staff training Apr - May 2026 **Testing & Refinement Phase** - Test procedures with sample clients - Refine processes based on feedback - Ensure all systems are operational - Complete any additional training - Final compliance readiness check 1 Jul 2026 **Obligations Apply** - All compliance obligations apply from this date - Apply procedures to all new engagements - Monitor compliance effectiveness - Document any issues for resolution ## Don't leave it too late Many businesses underestimate the time required to develop, implement and test an effective AML/CTF program. Common pitfalls include: - **Underestimating documentation time:** Developing and customising an AML/CTF program requires significant time and complexity varies widely by firm - **Delayed legal review:** Solicitors' availability in March-April 2026 may be limited as demand peaks - **Insufficient staff training:** Ensuring all team members understand their obligations takes time - **Technology challenges:** Setting up verification and record keeping systems may require IT support - **Process testing:** You need time to test procedures before they're required [ Read our complete Tranche 2 Guide Key dates, affected sectors, obligations and how to prepare ](/tranche-2) ### Get ahead of the deadline HeadStart Docs provides free AML/CTF program documents as a starting point, giving you time to prepare and work with your lawyer to customise for your business. [View AML/CTF Digital Products](/programs) **Disclaimer:** This article is general information only. It is not legal, financial or compliance advice. HeadStart Docs™ provides free compliance documents, not legal services. We do not guarantee the accuracy of information provided. Obligations may apply depending on your designated services. Always confirm your specific requirements with a qualified adviser. Need a lawyer to review your AML/CTF program? [HeadStart Counsel](https://headstartcounsel.com.au/get-started) offers fixed-fee tailoring from $1,800+GST. Separate entity and engagement. ### Related Articles [ Compliance Understanding AML/CTF Tranche 2 ](/tranche-2-resources/understanding-amlctf-tranche-2)[ Best Practices Building an effective AML/CTF program ](/tranche-2-resources/building-effective-amlctf-program) ### Free Compliance Tools [Implementation Timeline Key dates and milestones for Tranche 2 compliance ](/timeline)[Readiness Test Assess your compliance readiness in 2 minutes ](/risk-calculator)[Sanctions Screening Search Australian sanctions lists and country risk ](/sanctions-search) ### Ready to get compliant? Sector-specific compliance documents to help you build your AML/CTF program. 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