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Sector deep-dive 9 May 2026 6 min read

Do bookkeepers need an AML program? It depends on what you actually do

Most pure-bookkeeping work sits outside Tranche 2 — but the moment you form an entity, hold client money or advise on structures, you're back in scope.

By James Carter

The Institute of Certified Bookkeepers estimates around 30,000 practising bookkeepers in Australia. The good news for the profession is that day-to-day data entry, BAS preparation and payroll are not designated services. The complication is that many bookkeepers quietly drift into work that is.

Bookkeeping work generally OUT of scope

  • Data entry, bank reconciliation and management reporting.
  • BAS and IAS lodgement (separately regulated by the TPB).
  • Payroll processing for an established employer.
  • Software training and migration.

Bookkeeping work generally IN scope

  • Forming companies or trusts on behalf of a client.
  • Holding or moving client funds outside a strict reimbursement arrangement.
  • Acting as a registered office or providing nominee director services.
  • Advising on or executing structural changes that move money between entities.

What to do if you're partially in scope

Scope your service mix honestly, document the trigger criteria that move a client into the in-scope cohort, and pick a self-serve platform priced for low-volume reporting entities (TrustSoft and easyAML are both viable below A$300/month). If less than 5% of your book is in scope, a managed service is overkill.

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