Accountant guide

How a firm lodges with AUSTRAC

Let's start with the good news: tax returns and BAS on their own do not put the firm on AUSTRAC's list, because that work is not a designated service. If you do provide one, you enrol, you keep a file, and you lodge when a report is due. You lodge in AUSTRAC Online, and we can draft the report and help you export it. We do not lodge it for you, though.

We help you draft, and you lodge

The report still goes in through AUSTRAC Online, and once you get a receipt, you record its number against the reviewed draft. LINK supplies identity evidence as part of customer due diligence, but it does not send an SMR, a TTR, or the annual compliance report.

When you have to enrol

You become a reporting entity when the firm provides a designated service from Table 6 and there is a link to Australia. From that point, you enrol with AUSTRAC, keep a program and a customer due diligence file, and lodge the reports below whenever the trigger is met.

If the firm enrolled but does not actually provide a designated service, it's worth asking AUSTRAC to take you off the Roll. While you stay enrolled, you still owe the annual compliance report, even if the work never quite fitted.

Enrolment happens in AUSTRAC Online, where you create a user and then enrol a new business. You can save your progress for up to 14 days, and the confirmation email will have a receipt number and an AAN. AUSTRAC's page on how to enrol has the current steps. AUSTRAC's page on the new enrolment forms lists what you will be asked. Just so you know, accountants enrol rather than register, because registration is for remitters and virtual asset businesses, not for an accounting firm.

Professional designated services in Table 6

AUSTRAC publishes this list, and we've set it out below. They call these professional designated services, and in the Act they sit in Table 6 of section 6.

Table 6 of section 6. AUSTRAC calls these professional designated services.
Item What the service is
1 Helping a client buy, sell or transfer real estate
2 Helping a client buy, sell or transfer a body corporate, which is usually a company, or a similar legal arrangement
3 Holding or controlling money or property as part of a transaction
4 Helping with financing for a company or a similar arrangement
5 Selling or transferring a shelf company
6 Helping create or restructure a company or a similar arrangement
7 and 8 Acting, or arranging for someone to act, in specified positions in a company or a similar arrangement
9 Providing a registered office or a principal place of business

You'll notice that tax returns, BAS, and ordinary advice on their own are not on that list, so doing that work alone does not make the firm a reporting entity.

Responsibilities and portal support

What you get in the portal

The portal provides SMR and TTR drafts and exports for review. Your staff still need to check current reporting requirements, calculate deadlines and confirm successful lodgement. Please record the receipt against the reviewed draft, and keep in mind that other compliance records are still required.

AUSTRAC Online is the other half of the picture. Enrolment, the report itself, and the annual compliance report all happen there, and that login belongs to the firm. A consultant can only lodge if the firm has invited them into that same AUSTRAC Online account.

The steps, in order

  1. First, work out whether the firm provides a designated service from Table 6. Tax and BAS on their own are not enough.
  2. If it does, enrol in AUSTRAC Online no later than 28 days after that work starts, and keep the enrolment details current. You have 14 days after something changes.
  3. Keep a program and a customer due diligence file in storage that the firm owns.
  4. When a report is due, draft it in the portal and export it, and then log in to AUSTRAC Online and submit it. If a screen looks different from this page, please follow AUSTRAC.
  5. Once it's in, paste the receipt number back into the portal.
  6. While the firm is on the Roll and still provides designated services, lodge the annual compliance report in the window that AUSTRAC opens each year.

How the report actually goes in

For a transaction report, AUSTRAC's guide to reporting methods sets out a few ways in. Most firms will simply type one report at a time, which is also how you fix a report AUSTRAC sends back. If you have several of the same type, you can export a spreadsheet from AUSTRAC Online, fill it in offline, and then paste the rows back. The limit is 500 rows or 30 MB at a time, and if there are too many parties on the one report, it's easier to type it in instead.

Bigger practices sometimes upload a file built to AUSTRAC's format, but that still happens inside an AUSTRAC Online login, so ShareRing cannot press submit for you. Enrolment and the annual compliance report are ordinary web forms rather than those file uploads.

And when you log in, please use the screens AUSTRAC Online is showing you. Most firms that enrolled after March 2026 will get the current SMR and TTR forms.

The deadlines to watch

It really helps to assign a responsible person to each deadline. The tightest one is the terrorism financing SMR, which is due 24 hours from forming the suspicion.

24 hours SMR if the suspicion is about terrorism financing
3 business days Other SMR, after the day the suspicion was formed
10 business days TTR, after the day the cash transaction takes place
14 days Update enrolment details after something changes
28 days First enrol after the firm starts a designated service

There is also a 5 business day SMR clock if the firm claims legal professional privilege, and that clock is not for terrorism financing. Privilege claims are more common for lawyers than for accountants, but if you do withhold privileged material, you also lodge an LPP form.

What you lodge

Enrolment

You need to enrol if the firm provides a designated service, but not if it only does tax, BAS, or ordinary advice. Please enrol rather than register, since registration is for remitters and virtual asset businesses.

How Create an AUSTRAC Online user, and then enrol a new business. AUSTRAC's page on how to enrol has the current screens. You can save your progress for up to 14 days, and the confirmation email will have a receipt number and an AAN.
Time Apply no later than 28 days after the day the firm starts providing a designated service, and update details within 14 days of a change.
ShareRing You can record enrolment details here, while your staff track deadlines and enrol in AUSTRAC Online.

Suspicious matter report

There is no dollar minimum here. You lodge each time staff form a suspicion on reasonable grounds, even if they cannot identify the person, and even if they refuse the work. It applies when they start, propose, or are asked for a designated service. AUSTRAC's page on suspicious matter reports has the clocks and the form.

Once you submit the SMR, keep the working papers, the decision trail, and the receipt. Please remember that tipping-off is a criminal offence. If the firm keeps the client, it must do enhanced customer due diligence, although it does not have to end the relationship just because it lodged.

How Through AUSTRAC Online, using the SMR screens it shows you when you log in.
Time 24 hours if the suspicion is about terrorism financing, and otherwise 3 business days after the day the suspicion was formed.
ShareRing We help you draft and export it, and you still lodge in AUSTRAC Online.

Threshold transaction report

This one is about physical cash, not a tax return. You lodge a TTR when the firm provides a designated service involving $10,000 or more in physical cash, received or paid, including foreign cash of that value. If the firm never takes or pays that kind of cash, you can skip it. AUSTRAC's page on threshold transaction reports has that cash line.

Please don't add separate cash amounts together for a TTR. If staff suspect a client is splitting payments to stay under the line, that's an SMR rather than a rolled-up TTR.

How Through AUSTRAC Online, using the TTR screens it shows you.
Time 10 business days after the day the transaction takes place.
The cash line $10,000 or more in physical cash.
ShareRing We help you draft on that same $10,000 cash rule, and you still lodge in AUSTRAC Online.

Annual compliance report

You lodge this while the firm is on the Roll and provides designated services. In AUSTRAC Online, as an administrator, go to Business, then Compliance Reports, and then Open Compliance Report. ShareRing does not lodge this one either. AUSTRAC's page on annual compliance reports has the window and the questions.

The report covers the financial year from 1 July to 30 June. For the 2026 to 2027 year, AUSTRAC opens the form from 1 July to 30 September, and when it opens, it's best to use the dates and questions it shows you. A firm that first provides a designated service on 1 July 2026 should expect that 2026 to 2027 year to be its first one.

International funds transfer

This one usually isn't your report. It's for sending or receiving an international funds transfer instruction, and holding client money is not automatically that, so the bank typically lodges it. If it ever applies to the firm itself, the clock is 10 business days. AUSTRAC's page on international funds transfer reports is the one to check.

What to keep on file

You submit enrolment updates, the SMR, the TTR, the annual compliance report, an international funds transfer report if the firm itself sends or receives the instruction, and an LPP form if you withhold privileged material. Everything else stays in storage the firm owns, usually for 7 years, and please don't treat ShareRing LINK as that file. AUSTRAC's page on record keeping is the one to keep beside the file.

Record How long
Transaction records, enough to reconstruct the designated service 7 years from the day the record is created
Documents the client gave you for the transaction 7 years from the day you were given the document
Customer due diligence records 7 years from the end of the business relationship, or from finishing an occasional transaction
Program, risk assessment, training, and related evidence From when it was made until 7 years after it is no longer relevant. "No longer relevant" is professional judgement.
SMR and TTR working papers, internal logs, receipt numbers Keep the decision trail and restrict access, because tipping-off still applies.

Copies of identity documents are not strictly required if the procedure and the details used are recorded, although copies are still common when they live in storage the firm owns.

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