--- title: "Reporting Groups for Franchises | HeadStart Docs™" description: "Franchise networks can share one AML/CTF program via Reporting Groups under Section 10A. Learn how the Lead Entity model simplifies compliance." 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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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": "Reporting Groups", "item": "https://www.headstartdocs.com.au/tranche-2-resources/reporting-groups-franchise" } ] }, { "@context": "https://schema.org", "@type": "Article", "headline": "Franchise Compliance: How to form a Reporting Group under Section 10A", "description": "Multi-office agencies can share a single AML/CTF program through Reporting Groups. Learn how Section 10A enables franchise-wide compliance.", "datePublished": "2025-12-20", "dateModified": "2025-02-04", "url": "https://www.headstartdocs.com.au/tranche-2-resources/reporting-groups-franchise", "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) ![Multi-office franchise compliance](/assets/open-plan-office-Bj6Ewzk-.jpg) [Back to Free Resources](/tranche-2-resources) Updated February 2025 • Technical Compliance # Franchise Compliance: How to form a "Reporting Group" under Section 10A Multi-office agencies dread the thought of maintaining 10 or 50 separate AML/CTF programs. The good news: Reporting Groups under Section 10A allow franchises to operate under a single program with a Lead Entity approach. ## The problem: Multiple separate programs Under a strict interpretation, each reporting entity needs its own AML/CTF program. For a franchise network with 20 offices, that could mean: - 20 separate risk assessments - 20 separate AML/CTF policies - 20 separate compliance officers - 20 separate training programs This is administratively burdensome, expensive and creates inconsistency across the network. ## The solution: Reporting Groups (Section 10A) The reformed legislation introduces "Reporting Groups" under **Section 10A**, replacing the old "Designated Business Groups" (DBGs) concept. This allows related entities to operate under a shared compliance framework. ### Section 10A: Reporting Groups A Reporting Group is a group of reporting entities that have notified AUSTRAC they wish to be treated as a group for compliance purposes. Key features: - Group members share a common AML/CTF program - One entity acts as the "Lead Entity" with primary responsibility - Members adopt the Lead Entity's program - Reporting obligations can be centralised ### Important: Shared liability Both the Lead Entity and member entities retain liability for breaches. Forming a Reporting Group does not shift liability entirely to the Lead Entity. Each member remains responsible for compliance within their operations. ## The Lead Entity concept: Section 10A(5) Under **Section 10A(5)**, the Reporting Group must nominate a Lead Entity. This entity: #### Holds the program The Lead Entity maintains the group AML/CTF program, including the risk assessment and policies. Member entities adopt this program. #### Coordinates compliance The Lead Entity manages training, oversight and program updates for the entire group. A single Compliance Officer can be shared across multiple members under Section 26F(6). #### Centralises reporting Suspicious Matter Reports and other AUSTRAC reporting can be managed centrally by the Lead Entity on behalf of group members. ## Two types of Reporting Groups #### Business Groups Formed where there is a control relationship between entities (e.g. parent-subsidiary, corporate group structures). #### Elective Groups Formed by written agreement between entities that wish to be treated as a group (e.g. franchise arrangements). ## How this works for franchises For a real estate franchise network, the typical structure would be: ### Franchise Reporting Group Structure #### Lead Entity: Franchisor/Head Office - Develops and maintains the group AML/CTF program - Appoints a group AML/CTF Compliance Officer - Provides training materials and oversight - Manages AUSTRAC reporting and communication #### Members: Individual Franchise Offices - Adopt the group program via Member Entity Addendum - Implement procedures in day-to-day operations - Report suspicious matters through the Lead Entity - Attend training provided by the Lead Entity - Document any local variations from the group program ## Requirements to form a Reporting Group 1. **Eligibility:** Members must be related entities (corporate group, franchise arrangement or similar relationship) 2. **Notification:** The group must notify AUSTRAC of its formation and nominate the Lead Entity 3. **Program adoption:** All members must formally adopt the Lead Entity's program 4. **Ongoing compliance:** The Lead Entity must ensure all members remain compliant ## Cost and efficiency benefits For franchises, this structure offers significant advantages: - **Single program setup:** The franchise can get ONE set of AML/CTF program documents and share it legally across all offices - **Centralised expertise:** Compliance knowledge sits with the Lead Entity rather than being spread thinly across multiple offices - **Consistent approach:** All offices follow the same procedures, reducing risk of non-compliance - **Simplified auditing:** AUSTRAC reviews the group program rather than multiple individual programs ### Key Takeaway Section 10A allows franchise networks to form Reporting Groups with a Lead Entity structure. This means one program, one compliance officer and centralised oversight - rather than duplicating effort across every office. The Lead Entity (typically the franchisor) holds the program; members adopt it via addendum. Both lead and member entities retain liability for breaches. [View AML/CTF Digital Products](/programs) [ Read our complete Tranche 2 Guide Key dates, affected sectors, obligations and how to prepare ](/tranche-2) **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 Minimum Training Requirements ](/tranche-2-resources/minimum-training-requirements)[ Compliance Employee Screening obligations ](/tranche-2-resources/employee-screening-section-26f)[ Best Practices Building an effective 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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