The term ‘designated service’ has appeared in nearly every piece of Tranche 2 guidance published for the property industry, including AUSTRAC materials. Most of the written guidance is targeted at conveyancers and lawyers. The legislative definition is written in regulatory language, making it hard for real estate agents to understand what it means for the day-to-day running of their business.
Does listing a property, marketing it, running open houses, negotiating an offer and closing a sale count as designated services under the AML/CTF framework?
For most agents, the answer is yes, which means their business needs to enrol with AUSTRAC. However, existing guidance doesn’t quite spell it out directly. This article explains the definition in plain language, then maps it against the most common property professional roles, starting with real estate sales, so that every reader leaves with a clear answer and understanding of the reforms for their specific practice.
Under the AML/CTF Act, a designated service is a service that falls within a defined list and has a geographic connection to Australia. Before Tranche 2, that list covered banks, financial institutions and gambling operators. From 1 July 2026, it has extended to include property-related services for the first time, capturing real estate professionals, conveyancers, lawyers and certain other property practitioners. The scope centres on a core concept, which is facilitating the transfer or acquisition of property. While the framing is broad enough to cover a wide range of property services, it doesn’t capture every activity that a real estate agent carries out.
It’s important to understand three aspects of the definition before we discuss how it applies to various roles. Payment is not a prerequisite for an activity to be classified as a designated service. Assisting with the transfer of a property between family members without charging a fee can still fall under a designated service. The question is the nature of the activity, not whether consideration changes hands between the professional and the client.
It is the entity providing the service that has reporting obligations, not the client. If a professional is facilitating a property transaction, they become the reporting entity for that transaction.
The service does not need to result in a completed transaction. A professional who has negotiated on behalf of a client and prepared or executed a contract has provided a designated service, even if the transaction does not proceed to settlement.
While the three aspects create a foundation, it becomes even more important to ask what specific practices are subject to the reforms.
The following sections address how the reforms affect the most common roles in the property industry. We’ve identified information that’s clear and available. If it’s ambiguous, we’ve pointed it out directly.
Real estate sales is a designated service under AUSTRAC’s Tranche 2 framework. This applies to real estate agents and principals dealing in residential, commercial and rural property. The trigger is facilitating the purchase or sale of property on behalf of a buyer or seller. In the context of everyday activities, it covers:
An agent does not need to be involved at settlement for the service to be captured. If the agent is engaged on the listing side, or acting on behalf of a buyer in any part of the acquisition process, they have provided a designated service.
Real estate agents are now required to enrol with AUSTRAC, implement an AML/CTF compliance program and conduct due diligence on clients.
What conveyancing means as a designated service has been addressed extensively in guidance since the reforms were announced. It includes both conveyancers and solicitors who provide conveyancing services. Preparing legal documents, conducting title searches and managing settlement on behalf of a buyer or seller each constitute a designated service under the extended framework.
If your team is still working through implementation, PEXA Clear’s obligations guide provides a practical starting point. Read Your New AML Obligations as a Property Professional.
Buyer’s advocacy as a designated service is explained clearly for most buyer’s agents operating using the traditional model. The legislation states that acting on behalf of a buyer to identify, assess and negotiate the acquisition of real property is a designated service. It includes the following:
The nuance arises for an engagement that’s purely advisory, where a buyer’s agent is engaged to provide a written report or market opinion without facilitating a purchase. For the full breakdown of how the framework applies to buyer’s agents specifically
Off-the-plan sales are a designated service and have specific trigger points:
Adjacent roles, like project marketing roles that involve generating leads but not handling contracts or exchange, are ambiguous when it comes to obligations
Standard residential property management is not classified as a designated service under the AML framework. Routine leasing activity, including finding tenants, managing tenancy agreements, collecting rent, and conducting inspections, falls outside the designated services list under the current Tranche 2 framework.
The exception is when a property manager also facilitates the sale of a property they manage. That transaction is a designated service, and triggers the full set of AML/CTF obligations, regardless of the broader management relationship. For property managers who occasionally act in a sales capacity, the framework applies on a transaction-by-transaction basis.
Questions around commercial property management as an AML designated service are complex where management roles negotiate significant commercial leases or manage investment portfolios with ownership transactions. Those circumstances warrant closer review against the designated services list.
| Role | Typical activity | Designated service? |
| Real estate agent | Listing, marketi ng, negotiating, exchanging on behalf of selTypical activityler or buyer | Yes |
| Buyer's agent | Identifying, shortlisting, bidding, negotiating on behalf of buyer | Yes |
| Conveyancer/solicitor | Legal documents, title searches, settlement management | Yes |
| Off-the-plan sales agent | Contracting buyers for property yet to be built | Yes (check trigger points) |
| Property manager | Standard leasing, rent collection, tenancy management | No (standard leasing) |
| Property manager acting in sales | Facilitating the sale of a managed property | Yes, for that transaction |
| Advisory only | Written reports or opinions; no transaction facilitated | Likely no - assess engagement scope |
Not every practice fits neatly into the categories above, creating ambiguity around what attracts obligations and what doesn’t. Let’s acknowledge and address them.
If a property professional has been engaged solely to provide a written opinion or market assessment, this is not considered a designated service. But if the same professional is involved in a property transfer or acquisition, it’s captured as a designated service. The determining question is whether the professional is acting as an agent or facilitator in the transfer or acquisition of property, or functioning only as an adviser.
Practices that combine roles such as a buyer's agent who also manages the acquired property, or a principal who handles both sales and project marketing then they should assess each service line individually. The business as a whole is not the relevant unit of analysis. If any line of work constitutes a designated service, the practice is a reporting entity for transactions in that line, even if other parts of the business are not captured.
Referring a buyer to a property or connecting parties without facilitating the transaction is not, of itself, a designated service. However, where referral arrangements involve consideration linked to the transaction, or where the referring party helps in negotiation or contract execution, the position becomes less clear. AUSTRAC guidance continues to develop for this area.
Property services providers should map their specific activities against the designated services list instead of relying on general category descriptions. PEXA Clear’s designated services reference guide provides a structured way to do that.
Property professionals whose work clearly falls within one of the captured categories, you should already have confirmed enrolment with AUSTRAC, built an AML/CTF compliance program proportionate to the practice’s risk profile, and begun conducting customer due diligence.
The Designated Services Reference Guide, available through PEXA Clear, maps the most common property professional services against their Tranche 2 status in a single-page format. It provides a plain-language translation of the AUSTRAC designated services list, formatted to be kept on file and used during onboarding or client intake.
For practices operating in hybrid or ambiguous service models, the sibling guide, Residential only, small practice, low volume: does AML still apply to you? works through the scenarios most likely to generate uncertainty.
For those who have confirmed they are captured and are ready to understand the full scope of obligations, Your New AML Obligations as a Property Professional covers enrolment, program requirements and reporting obligations in full
Where PEXA Clear fits
The market does not need more information alone. It needs practical implementation support. PEXA Clear is a purpose-built AML/CTF compliance platform for real estate agents, conveyancers and buyer's agents. It embeds identity verification, risk assessment and AUSTRAC reporting into existing property workflows, so compliance runs alongside transactions rather than separately from them.
