Use the correct reporting period
An annual AML/CTF compliance report describes how the reporting entity met its obligations during the reporting period. It is separate from transaction reporting.
The financial-year period runs from 1 July 2026 to 30 June 2027. The submission period is 1 July to 30 September 2027.
Section 47 and Rules section 9-9 set the framework. Apply the relevant exemptions and special circumstances. A submitted report is not a certificate of compliance.
Sources: AUSTRAC: When to submit. How to submit. Who must submit; Federal Register of Legislation: Sections 6, 41, 43 and 47; Part 3.
Who submits for a reporting group
AUSTRAC says one group member should lodge the annual compliance report on behalf of the reporting group. The submitting member should tell the others because AUSTRAC does not notify each member. A member can submit its own report if its circumstances are substantially different from other group members. AUSTRAC describes the path in AUSTRAC Online: open Compliance Reports, find the submitted group report in the Existing Reports list and select the override link. Submission also requires administrator access in AUSTRAC Online. These details matter when assigning responsibility: group membership and an internal approval do not, by themselves, establish that the report was lodged.
Lodging for the group does not transfer each member’s obligations. The lead entity is responsible for group-wide AML/CTF policies, risk management and compliance management, and each reporting entity remains legally accountable for its own obligations. The reporting group guide explains the split.
Sources: AUSTRAC: Reporting groups; How to submit your report; AUSTRAC: How reporting groups function; Federal Register of Legislation: Section 6(6A).
- Member information
Collect the relevant information from group members.
- Submitting member
Examine the group arrangement, access and any applicable override.
- Submission evidence
Retain the receipt and tell the other members that the report was submitted.
From group information to a submission record
Read this visual with the source conditions and explanation in this section.
Follow the process from top to bottom.
Invented example: a change of compliance officer
Imagine a small business changes its compliance officer during the reporting period. The incoming officer should not assume that an empty training folder means no training occurred. In the example review, they examine attendance records, earlier reports and the handover notes. They distinguish missing evidence from a confirmed control failure. Where the record is incomplete, the answer and internal follow-up should reflect that limitation.
The purpose is an accurate account of the period, not a favourable narrative assembled from the newest documents.
Sources: AUSTRAC: When to submit. How to submit. Who must submit; Federal Register of Legislation: Sections 6, 41, 43 and 47; Part 3.
Review the answer before submission
A practical review confirms that the answer concerns the reporting entity and period named in the form. It also examines whether a group member is submitting on the entity’s behalf. Keep a record of who prepared and reviewed the answers. If different teams disagree about an answer, resolve the evidence question before submission. Do not use a planned improvement as evidence that a control already operated.
An honest distinction between implemented work, incomplete work and proposed work makes the record easier to understand and maintain.
Sources: AUSTRAC: When to submit. How to submit. Who must submit; Federal Register of Legislation: Sections 6, 41, 43 and 47; Part 3.
Keep a useful submission record
The example workflow retains the submitted report, confirmation and supporting evidence references. It assigns each identified improvement to an owner with a realistic due date. The next reporting cycle can then test whether that work was completed. Keep AUSTRAC account access and contact details under review so that staff changes do not obstruct submission. These are suggested operating steps.
Read the current guidance for eligibility, reporting groups and special circumstances. Different businesses may need to answer different questions.
Sources: AUSTRAC: When to submit. How to submit. Who must submit; Federal Register of Legislation: Sections 6, 41, 43 and 47; Part 3.