Industry Update
For the first time, real estate professionals across Australia, including those involved in commercial property and business transactions, will be required to complete formal identity verification, risk assessments, and record-keeping obligations for every transaction.
While these changes are primarily operational for agencies and advisors, they will also affect buyers and sellers directly, with additional documentation and verification steps expected throughout the sales process.
The reforms form part of AUSTRAC’s expanded AML/CTF regime, often referred to as “Tranche 2” reforms, which extend compliance obligations to additional industries.
New Compliance Requirements
From 1 July 2026, real estate and business transactions will involve increased verification, documentation and compliance obligations.
Confirm and document client and transaction participant details.
Evaluate and record risk factors relevant to the transaction.
Retain transaction and compliance documentation for at least seven years.
Identify and report suspicious activity where required.
The expanded regime will apply to industries including:
These obligations will apply nationally and affect residential, commercial and business-only transactions across Australia.
The reforms form part of AUSTRAC’s expanded AML/CTF regime, often referred to as “Tranche 2” reforms, which extend compliance obligations to additional industries.
New Compliance Requirements
From 1 July 2026, real estate and business transactions will involve increased verification, documentation and compliance obligations.
Confirm and document client and transaction participant details.
Evaluate and record risk factors relevant to the transaction.
Retain transaction and compliance documentation for at least seven years.
Identify and report suspicious activity where required.
The expanded regime will apply to industries including:
These obligations will apply nationally and affect residential, commercial and business-only transactions across Australia.
For most participants, the changes will introduce additional administrative and verification steps into the transaction process.
Depending on the nature of the transaction, parties may be required to provide:
✓ Proof of identity documentation
✓ Company or trust ownership information
✓ Source of funds information
✓ Beneficial ownership details
✓ Transaction structure documents
These requirements will improve transparency and reduce the risk of illicit financial activity within the Australian property market.
Importantly, these checks are expected to become a standard part of doing business nationally, rather than something specific to individual agencies or advisors.
For most participants, the changes will introduce additional administrative and verification steps into the transaction process.
Depending on the nature of the transaction, parties may be required to provide:
✓ Proof of identity documentation
✓ Company or trust ownership information
✓ Source of funds information
✓ Beneficial ownership details
✓ Transaction structure documents
These requirements will improve transparency and reduce the risk of illicit financial activity within the Australian property market.
Importantly, these checks are expected to become a standard part of doing business nationally, rather than something specific to individual agencies or advisors.
In the car wash sector, transactions often involve a combination of business assets, property interests, entities, trusts and financing arrangements. As a result, preparing accurate documentation early is likely to become increasingly important under the new framework.
This may mean ensuring ownership structures, financial records and entity information are clear and readily available before going to market.
For buyers, particularly those purchasing through companies, SMSFs or trust structures, additional verification requirements may apply during due diligence and settlement.
Well-prepared transactions are generally easier to progress through legal, finance and compliance processes, helping reduce delays once a deal is underway.
Completed: Review structures, records and documentation.
Early 2026: Expect process and compliance updates across the sector.
1 July 2026: New AML/CTF obligations commence.