The Australian Government’s new Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws are designed to combat financial crime.
While few people would disagree with that broad objective, in practice it is the everyday law-abiding Australian who will ultimately bear much of the cost.
For accounting firms, including SMSF specialists like us and other professional advisers, these laws create an entirely new layer of compliance that must be built, maintained, monitored and audited.
For a specialist SMSF establishment business, implementation is not a matter of updating a few forms. It means:
- Developing a documented AML/CTF compliance program
- Undertaking firm-wide risk assessments
- Implementing client identification and verification systems
- Establishing beneficial ownership checking procedures
- Creating source-of-funds verification processes
- Training every staff member
- Conducting ongoing monitoring and reviews
- Maintaining extensive compliance records
- Updating procedures whenever regulations change
- Preparing for regulatory reviews and audits
The cost of this work is substantial.
Based on our assessment, specialist SMSF firms can spend 500 hours or more designing, implementing and maintaining the systems, processes and staff training required to comply with the new AML/CTF regime.
For many firms, the direct implementation cost is likely to exceed $50,000, before accounting for the ongoing compliance burden that will continue year after year.
Every new SMSF establishment will require additional client verification, risk assessment, documentation and record keeping. Even straightforward client engagements are expected to involve one to three additional hours of compliance work, with more complex structures requiring significantly more.
These costs do not disappear.
They become part of the ongoing cost of providing professional services.
When governments introduce new regulatory obligations, businesses have three options: absorb the cost, reduce service levels, or pass the cost on to consumers. Most firms will end up doing some combination of all three.
Unless they close. These requirements are simply not feasible for every small business to adopt, which may accelerate the trend towards larger and larger providers as smaller firms struggle to absorb increasing regulatory burdens.
The objective of the legislation may be well-intentioned. However, it is important to recognise that the financial burden does not fall on government.
It falls on small businesses, professional advisers and ultimately the clients who rely on their services and who may prefer a specialist provider to a faceless corporate alternative.
What Will Change From 1 July 2026?
While the new AML/CTF obligations will significantly increase our compliance costs, we have chosen to keep our SMSF establishment fee at $2,900 + GST. However, from 1 July 2026, the ASIC company trustee registration fee will no longer be included within our SMSF establishment fee and will instead be charged separately at cost ($636).
This change reflects the significant additional compliance, verification, risk assessment, documentation and record-keeping obligations now required under the new AML/CTF regime. Rather than increasing our professional fee by the full amount of these additional costs, we have chosen to separately disclose the ASIC registration fee so clients can clearly see the government and third-party costs associated with establishing an SMSF.
Clients should also expect additional information and documentation requests throughout the establishment process as we satisfy our legal obligations under the new AML/CTF regime.
Importantly, our standard SMSF establishment timeframe will increase from 4–6 weeks to 6–8 weeks, reflecting the additional verification, compliance and documentation requirements that must now be completed before a fund can be established.
We appreciate that no client welcomes increased costs or longer timeframes. However, these changes are the direct result of mandatory regulatory requirements that now apply across the industry.
We remain committed to providing specialist SMSF services, personalised support and high-quality service, and we thank our clients for their understanding, patience and cooperation as these changes are implemented.
Your assistance in providing information promptly and responding to compliance requests will help us meet our legal obligations efficiently while continuing to deliver the service standards you expect from us.