KYC and AML/CTF obligations for accountants: everything you need to know before July 1

What’s changing from July 1? 

Australia’s AML/CTF (Anti-Money Laundering and Counter-Terrorism Financing) laws are expanding. From July 1, 2026, a broader range of professional service providers, including accountants and some bookkeepers, will become “reporting entities” under the Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act).

For many practices, this means more admin, more documentation, and more time spent on compliance that doesn’t directly benefit your clients or your bottom line.

This is a significant change. For the first time, your practice will need to:

• Enrol with AUSTRAC as a reporting entity (enrolment is open now and must be completed by 29 July 2026)

• Appoint an AML/CTF Compliance Officer at management level

• Develop an AML/CTF program including a money laundering, terrorism financing and proliferation financing risk assessment tailored to your practice

• Conduct customer due diligence (CDD) on your clients before providing certain designated services

• Monitor for and report suspicious matters to AUSTRAC

• Keep records in accordance with the Act

It’s a real compliance uplift. For many practices, the CDD requirements will be the most operationally intensive part: verifying the identity of clients and beneficial owners, understanding the purpose and nature of the business relationship, and keeping that information current on an ongoing basis.

What is KYC and CDD, and why does it matter for your practice? 

CDD (customer due diligence) is the formal framework that sits behind what’s commonly called KYC (Know Your Customer). CDD is the process of verifying who your client is, understanding the nature of their business, and assessing the money laundering and terrorism financing risks associated with providing your services to them. It’s been a standard requirement for banks and financial institutions for years. From 1 July, it applies to you too.

The practical implication: before you provide certain designated services to a client, you need to identify and verify them. That means collecting identification documents, verifying identity against reliable sources, identifying beneficial owners for companies and trusts, and keeping that information up to date.

If you’re also referring clients to platforms like pay.com.au, your client will go through a separate CDD process as part of their onboarding with us. That’s where our CDD reliance arrangement can save you time.

How pay.com.au can help: CDD reliance for referred clients 

The pay.com.au Advisor Program includes access to our CDD solution built specifically for accountants and bookkeepers. 

When your client signs up to pay.com.au through your referral, we verify their identity as part of our onboarding process. We’re an existing AUSTRAC-enrolled reporting entity and we take our CDD obligations seriously. 

Here’s how it works:

1. Complete a one-time CDD reliance agreement
   You sign a CDD Reliance Agreement with pay.com.au, that establishes the formal reliance arrangement between your practice and pay.com.au under the AML/CTF framework. Our AML Officer countersigns each agreement.
2. Refer your client
   Share your unique referral link. When your client signs up and completes onboarding on pay.com.au, their KYC verification happens as part of the process.
3. We verify them and let you know
   Once your client is fully verified, you’ll receive a confirmation email from our team. You can rely on this confirmation for your CDD obligations under the reliance agreement.

That’s it. One form, one agreement, and from that point forward, every client you refer through pay.com.au is verified as part of their onboarding.

What do you need to do before July 1? 

For existing Advisors: Ready to get set up before July 1? Book a call with your Partner Manager to go through the next steps. They’ll walk you through the reliance agreement and send you the form to get started.

Book a call →

For non-advisors: Not in the Advisor Program yet? Join first, then book a call with your Partner Manager, who will talk you through the CDD reliance arrangement alongside everything else the program offers.

Join the Advisor Program →

Regardless of whether you use pay.com.au: Start preparing for 1 July now. AUSTRAC has published program starter kits specifically for accountants and other newly regulated entities. Your industry association may also have guidance. If you haven’t already, speak with a legal adviser about your specific obligations. 

Questions?

Is the KYC reliance solution available to all advisors? It’s available to all members of the pay.com.au Advisor Program. If you’re not yet a member, you’ll need to join first. It’s free and takes minutes.

Do I need to complete the reliance form for every client? No. The CDD Reliance Agreement is a one-time agreement. Book a call with your Partner Manager and they’ll send it to you directly. Once signed, it covers all clients you refer through your unique referral link.

Does the reliance arrangement cover all of my AML/CTF obligations? No. The arrangement allows you to rely on pay.com.au’s customer identification and verification for clients you refer to us, reducing duplication and saving you time. You’ll still need your own AML/CTF program and risk assessment for your practice (every Tranche 2 reporting entity does) and may need to collect additional client information beyond identity verification depending on the services you provide. Think of it as one less thing to worry about. 

What confirmation do I receive when a client is verified? You’ll receive an email from our team confirming that customer identification procedures have been completed for your referred client. You can rely on this confirmation for CDD purposes under the arrangement.

Does the agreement need to be renewed? The AML/CTF Rules require CDD arrangements to be reviewed at regular intervals, not exceeding two years. We’ll work with you to make sure the arrangement stays current.  

When does this go live? July 1, 2026. We recommend getting your reliance agreement in place before that date.

Written by Christina McDonald

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