28/10/2025
We know there’s confusion about what’s in and out under Tranche 2 of the upcoming Anti Money Laundering legislation (AML) in respect to BAS Agents. Australian Bookkeepers Association, together with other associations (including CPA Australia), is actively engaging with the regulator (AUSTRAC) to secure clear guidance—particularly on accounts payable where an agent is a co-signatory to a client’s bank account, and on payroll services as we have seen much misinformation circulating.
Claims that the mere preparation of payroll is an AML reportable item are unfounded. While AUSTRAC materials reference “preparing payroll for other businesses,” the legislative hook is specific: cash-based payroll processors—i.e., a business that collects physical cash and uses that cash to make payroll payments. See AML/CTF Act 2006, s 6 (Table 1), Item 52. This provision has existed since 2006; it is not a new inclusion under the recent reforms. In addition, we are seeking clarification in respect to accounts payable issues and the relevant exclusions in the legislation around what are designated services and whether such services directly advance the planning or ex*****on of a transaction as called for by parliament, or whether they are merely incidental in the day to day operation of a business.
We are not providing guidance in this post—only noting current uncertainties. Australian Bookkeepers Association will continue working with peer bodies and AUSTRAC and will update members as soon as formal clarification is confirmed. Please don’t be spooked by unfounded commentary; rely on updates from your association once a position is confirmed.
