The 2026 AML/CTF reforms: what changes when you use a director or registered office service

Since 1 July 2026, businesses that act as, or arrange for someone to act as, a director or secretary of a company on behalf of another person, and businesses that provide a company's registered office address, provide "designated services" regulated by AUSTRAC. In practice, if your Australian company uses a resident director service or a third-party registered office, the provider must identify your company, its beneficial owners and the purpose of the relationship before it starts, and keep checking afterwards.

This guide is written from the client's side: what the reforms require of providers, what you will be asked for, and what you can't expect them to tell you.

What the reforms switched on

The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 extended Australia's AML/CTF regime to a group sometimes called tranche 2: lawyers, accountants, conveyancers, real estate professionals, dealers in precious stones and metals, and trust and company service providers. AUSTRAC's reform page confirms these businesses are regulated from 1 July 2026. Changes to program and due diligence rules for businesses that were already regulated started earlier, on 31 March 2026, and the revised tipping-off offence started on 31 March 2025.

The three services that matter for foreign-owned companies

AUSTRAC lists nine new professional designated services. Three touch almost every overseas group with an Australian subsidiary:

Item 5, selling or transferring a shelf company, and item 8, nominee shareholders, also apply to some groups.

A few details from AUSTRAC's professional services guidance are worth knowing:

• "Arranging" is caught, not just "acting". Identifying or introducing a person to be appointed, or drafting the appointment documents, can be part of the item 7 service. An adviser who finds you a director can be in scope as well as the director provider.
• AUSTRAC describes "acting as" a director on behalf of a customer as an arrangement where the customer retains control over how the director fulfils their duties and the director acts on the customer's wishes and instructions. Whether a particular appointment fits that description depends on its facts. Expect professional providers to treat their service as in scope and run full checks.
• Purely administrative agents are not, by that fact alone, in item 7. A filing agent who only carries out procedural steps is not acting in the role.
• In-house appointments sit outside. AUSTRAC regulates services to an external customer, not services to a member of the provider's own business group. A parent company executive who sits on the subsidiary's board is not providing a designated service.
• The address service starts early. Item 9 begins when the address is made available for use as the registered office, even before it is lodged with ASIC. It applies whether the address is paid for or free, and it needs a physical street address, not a PO box.

What you will be asked for

Before providing a designated service, the provider must complete initial customer due diligence (CDD). AUSTRAC's initial CDD overview lists what must be established on reasonable grounds:

1. Who the customer is, verified.
2. The beneficial owners, if the customer isn't an individual. A beneficial owner is an individual who directly or indirectly owns 25% or more, or otherwise controls the customer. For a subsidiary several layers below a listed or private group, that means looking through every layer to the people at the top.
3. Whether anyone involved is a politically exposed person (PEP) or designated for targeted financial sanctions. This covers the customer, its beneficial owners and people acting for it.
4. The nature and purpose of the relationship. Why does the company need an Australian director or address, and what will it do?
5. Source of funds and source of wealth, where a foreign PEP is involved or enhanced checks are needed because of higher risk.

Expect a structure chart that goes to the individuals, certified identity documents for each beneficial owner and director, the constitution if the company has one, and a plain description of the business and how it is funded. If your group has a trust, a fund or nominee shareholders anywhere in the chain, flag it up front. Those are the points where checks stall.

After onboarding

Due diligence doesn't end at appointment. Providers must keep monitoring for unusual activity and review and re-verify customer information at a suitable frequency, or when they have doubts about it. Changes in ownership, a new line of business or a sudden request outside the agreed scope, such as signing a guarantee for a related party, are typical triggers for fresh questions.

Records of the due diligence are kept for 7 years after the relationship ends. A provider can't delete your file early because you've moved on.

Existing clients from before 1 July 2026

AUSTRAC's transition guidance treats a customer as a pre-commencement customer if the provider was already providing the service on 1 July 2026, or had an ongoing relationship involving a designated service before then. Those customers can keep receiving the service without new initial CDD unless either:

• a suspicious matter reporting obligation arises, or
• the nature and purpose of the relationship changes significantly and the risk becomes medium or high.

Ongoing CDD applies regardless. So a long-standing client may still be asked to refresh documents, especially when it asks for a new kind of service.

What a provider can't tell you

Tipping off is an offence. A provider that has lodged, or is considering, a suspicious matter report can't disclose that to you, your parent company or your advisers where it would prejudice an investigation. If a provider declines to act and won't explain in detail, that is not necessarily obstruction.

Each regulated business must also enrol with AUSTRAC no later than 28 days after it starts providing a designated service, according to AUSTRAC's enrolment overview. If your bank or auditor wants comfort about a provider's AML/CTF status, ask the provider for a written statement.

Practical consequences for your group

• Onboarding takes longer if the ownership pack is weak. Most delays come from incomplete look-through to the individuals, not from the provider's process.
• Some arrangements won't be accepted. Providers will decline structures designed to hide who owns or controls the company, and directors who are expected to sign without information.
• Your Australian advisers may each run their own checks. One clean set of certified documents and a current structure chart saves weeks.
• Your own registers must match. The provider will compare what you tell it with the members register and the ASIC record. See company registers and beneficial ownership.

Crypto and payments businesses have separate AUSTRAC registration rules for their own services; see crypto and fintech.

Where AG Resident Directorship fits

Our onboarding includes identity, beneficial ownership and sanctions checks for every client, and we complete due diligence before any appointment. If you need a written statement of our AML/CTF position for a bank or auditor, ask and a person will reply. We don't give legal advice on whether your own business is regulated; an AML/CTF lawyer should answer that. For the questions worth asking any provider, see choosing a resident director service.

General information as at 27 October 2026, not legal advice. AUSTRAC guidance changes, so confirm the current position with an AML/CTF adviser.

General information about Australian law and practice, not legal or tax advice for your circumstances. Check the official sources, or ask your adviser, before you act.