Do accountants and lawyers need to perform CDD on existing clients?
No, existing clients on 1 July 2026 are pre-commencement customers and do not need fresh initial CDD, unless an SMR trigger arises or the relationship materially changes.
No - you do not have to re-do CDD on every existing client on 1 July 2026.
Under AUSTRAC's transitional rules, anyone you were in a business relationship with on 1 July 2026 for a designated service is a "pre-commencement customer." You can keep providing services to them without doing initial CDD, unless one of these triggers happens:
- You form a suspicion about the customer (an SMR obligation arises), or
- The relationship significantly changes in a way that pushes their ML/TF risk to medium or high - for example, they ask for a new type of service that's different to what you've been providing.
You do still have ongoing obligations for pre-commencement customers: monitor them for unusual activity, keep their KYC information current, and watch for changes in their risk profile.
You must also: review, update and reverify know your customer (KYC) information relating to the customer at an appropriate frequency. This includes if you’ve doubts about the KYC information’s adequacy or veracity
A customer stops being "pre-commencement" the moment you complete the initial CDD on them - typically because one of the triggers above kicked in.
Source: AUSTRAC, Transitioning existing customers (Reform).
Related articles
- Glossary: Key Terms & Definitions
- Pre-commencement customers - what CDD obligations apply, and the risks of not completing initial CDD
- How does CDD work for an off-the-plan purchase where settlement is years away?
- What do we need to do about our existing clients on 1 July 2026?
- Is there an additional charge for ongoing monitoring?