26/05/2026
Australian Bookkeepers Association and The Institute of Certified Bookkeepers
(The Joint Bodies)
Important information regarding AML/CTF Reform and BAS Agent / Bookkeeper Payment Authority Arrangements
The Joint Bodies earlier today, met with senior AUSTRAC officials and a representative of Minister for Home Affairs Office (The Hon Tony Burke MP), to discuss the application of the incoming AML/CTF Tranche 2 reforms as they relate to BAS Agents and professional bookkeepers. In particular, where BAS Agents/bookkeepers assist small business clients with payments relating to payroll, superannuation, and ordinary creditor payments (Item 3 Table 6)
A key area discussed was the practical scenario where a bookkeeper has client-authorised access to a business bank account, including dual-authority arrangements, and assists with routine business payments (under client authority), as part of a broader bookkeeping, payroll, BAS and accounts payable engagements.
The Joint Bodies received clarity from AUSTRAC, that where such a service is the only service being provided by the agent, and the service forms part of broader bookkeeping/BAS Service, then this is not considered a designated service and BAS Agents/bookkeepers will be excluded from AML/CTF enrolment requirements under the carve-out provided by Section 6(5C)(b).
In many small businesses, the bookkeeper is relied upon because they understand the payroll, superannuation, tax, cashflow and accounts payable position of the business. This work is performed under clear client authority and as part of the ordinary bookkeeping function, not as a standalone money service, remittance service, trust account service or client asset management service.
The Joint Bodies also raised the need for clear, practical and sector-specific guidance and examples, so that BAS Agents and bookkeepers can properly understand when they are, and are not, required to enrol under the AML/CTF legislation.
AUSTRAC is cognisant of the concerns raised, and further guidance from the regulator in respect to Item 3 Table 6 is expected imminently . The Joint Bodies were invited to continue to work constructively with AUSTRAC to seek clarity for members and the broader bookkeeping profession.
At this time, our message to the Bookkeeping/BAS Agent profession is simple: do not panic, but do pay attention to your approval processes when handling client funds.
The AML/CTF reforms are significant, and some BAS Agents and bookkeepers may be affected depending on the services they provide. However, the practical application of the rules to ordinary small business payment arrangements was made clear.
The Joint Bodies will provide further updates to the profession as soon as that additional AUSTRAC guidance becomes available.
In the meantime, members should carefully review their service offerings, engagement letters and banking authority arrangements, but should avoid making premature decisions to enrol with AUSTRAC based on fear-based or speculative commentary.
