From 1 July 2026, Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) identity verification became a legal requirement for accountants, along with lawyers, conveyancers, real estate agents and a handful of other professions, whenever they provide certain services in Australia.
The change comes from Australia’s “Tranche 2” reforms to the AML/CTF Act 2006, which bring accounting, legal and real estate firms, among others, under the oversight of the Australian Transaction Reports and Analysis Centre (AUSTRAC) for the first time.
So if your solicitor or real estate agent has started asking similar questions lately, that’s not a coincidence. It’s the same reform, applied across every profession it covers.
For most clients, verification is quick, secure and only needed once per service type. Here’s what’s changed, which of our services trigger it, and what to expect when we ask for your ID.
What is AML/CTF Identity Verification?
AML/CTF identity verification is the legal check accountants must now complete to confirm who they’re dealing with before providing certain “designated services.” It applies because Wardle Partners Accountants & Advisors, like all accounting firms, is now regulated by AUSTRAC for a defined set of higher risk activities.
Accountants are often described as “gatekeepers” of the financial system. We help form companies and trusts, restructure ownership, and manage significant asset transactions. In rare cases, these activities can be misused to disguise the origin of funds. The Tranche 2 reforms close a gap that had left Australia out of step with international standards set by the Financial Action Task Force (FATF) and bring us in line with the checks banks have run for years.
Importantly, the rules are service-specific, not relationship-specific. Even if you’ve been our client for a decade, a new designated service triggers a fresh check.
It’s also worth knowing this isn’t a Wardle Partners Accountants & Advisors policy, or even something unique to accountants. The same law applies to lawyers and conveyancers, real estate agents and agencies, and trust and company service providers, among others. If more than one of your advisers asks for the same documents around the same transaction, that’s the reform working as it’s meant to, not duplicated effort on our part.
Which of our services require ID checks?
You’ll need to verify your identity whenever the team provides a “designated service,” meaning a defined set of activities the Act treats as carrying higher money laundering or terrorism financing risk. Routine work generally sits outside this list.
Designated services include:
- Incorporating a new company or changing ownership structures
- Creating or restructuring family, discretionary or unit trusts
- Certain high-value property or asset transactions
- Managing client funds or property in relevant contexts
- Providing registered office services or acting in a nominee role
If you’re a Self-Managed Super Fund (SMSF) trustee restructuring a trust, or a business owner exploring a new company structure, this is where the new checks apply. By contrast, preparing your annual tax return and financial statements generally doesn’t trigger a new identity check, provided no designated service is involved and your details haven’t changed.
What documents will you need to provide?
For individuals, we need to verify your full legal name plus either your date of birth or residential address. A current Australian passport or driver’s licence (including digital licences) usually covers this in one step.
Where a single photo document isn’t available, we can combine documents, such as a Medicare card, recent utility bill or bank statement, alongside other ID. Most verification now runs through secure digital platforms, so documents can be uploaded and checked electronically in minutes.
For companies and trusts, we also need to identify and verify beneficial owners (generally anyone with 25% or more ownership or control), along with key controllers of the entity.
What are Politically Exposed Person (PEP) and sanctions checks?
As part of the verification process, software automatically screens your name against relevant databases. This checks whether you, or a close family member or associate, are a PEP, meaning someone who holds or has held a prominent public role, or appear on an Australian or international sanctions list.
This screening is a standard requirement applied to every client, not a judgement on any individual. It runs quietly in the background as part of the same process as your document check.
Is your personal information secure?
Yes. Our team handles your documents in line with the Privacy Act 1988 and the Australian Privacy Principles, using bank-grade encrypted verification platforms. Your original documents aren’t retained at all: our verification software automatically destroys them once your identity has been checked. What we keep on file is proof that the verification took place, not the documents themselves, and we hold that record for seven years, as required.
Can we start work before verification is complete?
No. By law, Wardle Partners Accountants & Advisors cannot begin a designated service until customer due diligence is complete and we’re reasonably satisfied as to your identity. This isn’t a formality we can skip, even for long-standing clients.
The sooner you provide your documents, the sooner we can get moving on your company, trust or structuring work. Delays in verification are the most common reason a straightforward engagement gets held up.
Conclusion
If you’re planning to set up a company, restructure a trust, or move into a new asset arrangement, factor identity verification into your timeline early. Speak with your accountant before you need the paperwork finalised. It’s a five-minute conversation that avoids a last-minute holdup. Get in touch with the team if you’d like to check whether your upcoming engagement is affected.
Frequently Asked Questions
Why did I get this request even though I’ve been a client for years?
The law focuses on the specific service being provided, not how long you’ve been a client. A new designated service, for example setting up a company or trust, automatically triggers a fresh identity check. That is regardless of your history with our team.
Is this only an accounting firm thing?
No. The Tranche 2 reforms apply to a wide group of professions, including lawyers and conveyancers, real estate agents and agencies, and trust and company service providers, alongside accountants. If more than one of your advisers asks for the same ID over the course of one transaction, that’s the reform in action, not a Wardle Partners Accountants & Advisors requirement.
Does this apply to my ordinary tax return?
Generally, no. Routine individual tax compliance work that doesn’t involve a designated service doesn’t trigger a new identity check, provided your details on file haven’t changed.
What exactly is a “designated service”?
It’s one of the specific activities listed in the AML/CTF Act’s professional services table. For accountants, common examples include company and trust formation or restructuring, certain asset management activities, and registered office services. Your Wardle Partners accountant can confirm whether your engagement is caught.
What if I don’t have a passport or driver’s licence?
Alternative document combinations are accepted, for example a Medicare card with a utility bill or bank statement. Your adviser will guide you through suitable options, including digital driver’s licences where available.
Will my details be shared with AUSTRAC?
Only in specific circumstances, such as suspicious matters or threshold transactions. Routine identity verification records stay with us, subject to the Privacy Act.
How long does verification take?
For most clients with standard documents ready, digital verification is usually completed within minutes. Delays typically only occur for higher risk situations or complex ownership structures.
References:
- AUSTRAC, AML/CTF Reforms Overview: https://www.austrac.gov.au/
- AML/CTF Act 2006 (and 2024 Amendments): https://www.legislation.gov.au/
- ATO, Client Verification Guidance for Tax Practitioners: https://www.ato.gov.au/
- Tax Practitioners Board, Proof of Identity Guidance: https://www.tpb.gov.au/
