Key Dates and Deadlines

Every deadline mentioned in this knowledge base, in one place. Each row links to the page that covers it in full.

The two anchor dates

31 March 2026 is when AUSTRAC enrolment opened for Tranche 2 entities. 1 July 2026 is when the obligations themselves commenced.

Enrolment could open early, on 31 March 2026, but it was not required before 1 July. A firm must apply to enrol no later than 28 days after it first provides a designated service. Enrolment is covered on Enrol with AUSTRAC.

Getting set up

Obligation or action	Deadline	What starts the clock	Source
Enrol as a reporting entity	Within 28 days (s 51B(1)). A civil penalty provision	First providing a designated service. For a firm providing services from 1 July 2026, the deadline is 29 July 2026	Enrol with AUSTRAC
Appoint an AML/CTF Compliance Officer	Within 28 days	Starting to provide a designated service (s 26K(1)). That is 1 July 2026 only if the firm was providing designated services then	Appoint your AMLCO
Notify AUSTRAC of the AMLCO appointment	Within 14 days (s 26M(1)). For a Tranche 2 firm's first AMLCO, by 29 July 2026 or 14 days after enrolling, whichever is later	The designation itself, not the same date the 28 day clock starts	Appoint your AMLCO
Have an approved AML/CTF program	Before providing a designated service	Becoming a reporting entity	Build your program

Note on the AMLCO rows: the 28 day and 14 day clocks start from different events. The 14 days run from the designation, not from the day the firm started providing services. For a Tranche 2 firm's first AMLCO, AUSTRAC's transitional rule gives until 29 July 2026 or 14 days after enrolling, whichever is later.

Customer due diligence

Obligation or action	Deadline	What starts the clock	Source
Complete initial due diligence	Before the designated service commences	The decision to provide the service	Customer due diligence
Delayed CDD, general route	As soon as reasonably practicable, and no later than 20 business days	Commencing the service. Always before money or property is transferred or made available	Customer due diligence
Delayed CDD, real estate transaction	28 days after exchange of contracts, or 3 days before the initially agreed settlement day, whichever is earliest	Exchange of contracts	Customer due diligence

Two things about delayed CDD

The real estate window is one window for both roles. A real estate agent delaying due diligence on the party they are not acting for, and a legal practitioner or conveyancer acting for a buyer or transferee, are on the same rule.

The settlement limb is anchored to the initially agreed day. A settlement that slips does not extend the deadline, and one brought forward does not pull it in.

Reporting to AUSTRAC

Report	Deadline	What starts the clock	Source
SMR, terrorism related	24 hours	Forming the suspicion	Reporting
SMR, all other grounds	3 business days	Forming the suspicion	Reporting
SMR, where part of the grounds is privileged	5 business days	Forming the suspicion. An LPP form accompanies the report. Terrorism financing stays at 24 hours	Reporting
TTR	10 business days	The day the transaction takes place, under s 43(2)	Reporting
CBM, carrying instruments through customs	Before customs	Arriving or departing	Reporting
CBM, sending instruments out of Australia	Before sending	Mailing or shipping	Reporting
CBM, receiving instruments from outside Australia	5 business days	Receipt	Reporting
ACR	1 July to 30 September each year	The end of the financial year reporting period	Reporting

Three of these are easy to get wrong:

• Most of these are business days, not calendar days. Ten business days is two working weeks, and a public holiday inside the window extends it.
• The CBM rule depends on the situation, not the direction. An inbound traveller carrying instruments reports before customs, not within 5 business days. The 5 business day window applies to instruments received from outside Australia.
• The first ACR for a Tranche 2 firm is due by 30 September 2027, covering the 2026 to 2027 financial year.

Not 31 March

Some older material states the annual compliance report is due by 31 March. That was the previous calendar year schedule, and it does not apply to a Tranche 2 entity whose obligations began on 1 July 2026.

Keeping records

Obligation or action	Deadline	What starts the clock	Source
Retain customer identification records	7 years	The end of the business relationship, or the completion of the occasional transaction (s 111(2))	Record keeping
Retain transaction records	7 years	The day the record is made (s 107(3))	Record keeping
Retain reports made to AUSTRAC	Until 7 years after the record stops being relevant to demonstrating compliance	Kept from when the record is made (s 116(3))	Record keeping
Retain AML/CTF program versions	Until 7 years after the record stops being relevant to demonstrating compliance	Kept from when the record is made (s 116(3))	Record keeping

Reviewing and evaluating

Obligation or action	Deadline	What starts the clock	Source
Review and update the AML/CTF policies	At the intervals the Rules specify, and at least once every 3 years	The last review	Review and evaluation
Independent evaluation of the program	At least once every 3 years, and at a frequency appropriate to the firm	The last evaluation. First evaluation deadlines are staggered under the transitional rules	Review and evaluation
AMLCO report to the governing body	At least every 12 months	The last report	Appoint your AMLCO

Operational cadences in Duely

These are product behaviours rather than legal deadlines, and they are listed separately so the two are not confused.

Item	Cadence	Source
AML program review prompt in the Action Center	12 months after the program's approval date	Compliance calendar
Report record deadlines	Calculated when the record is created, with the AMLCO notified as it approaches	Filing a report
Customer due diligence reviews	Raised when a customer's circumstances change, a baseline expires, or a trigger fires	Onboarding a customer

The program review prompt is earlier than the obligation

The Action Center prompts for a program review 12 months after approval and labels it "annual review". The statutory requirement is at least once every 3 years.

The product prompts earlier than the law requires, which satisfies the minimum, but do not read the product's cadence as the legal one. See Review and evaluation.

Where the deadlines are tracked

The Action Center holds firm level deadlines that fall due on a cadence, such as program review, training, and personnel due diligence. Per matter customer due diligence follow-ups live in the Monitoring Queue instead.

Report deadlines are tracked on the report records themselves. See Compliance calendar.

Related pages

• Glossary, for the terms used in these tables.
• Known limitations, for what Duely does not do.
• Reporting, for the report types in full.
• Record keeping, for the retention obligation.