How can reporting groups be formed under AUSTRAC's framework?

Overview

On 31 March 2026, Designated Business Groups (DBGs) were replaced by Reporting Groups under the reformed AML/CTF Act, and easyAML supports the new framework natively. For Tranche 2 entities there's no DBG legacy to consider - the Reporting Group is the only relevant grouping mechanism from day one. AUSTRAC defines two ways a reporting group can form.

1. Business groups (control-based)

Forms when two or more entities sit within a control structure (one controls the other, or they're under common control) and all members agree in writing on a lead entity. AUSTRAC takes a broad view of "control structure"; importantly, you can't selectively include only some entities - if a business group forms a reporting group, every member of the control structure must be included. This is the typical structure for related law firms, accounting practices or real estate offices under common ownership.

2. Elective reporting groups (election-based)

Two or more reporting entities not necessarily related by control can elect in writing to form a reporting group - the framework for unrelated firms sharing compliance infrastructure, such as a franchise network or professional association. A business-group member can also join an elective group, but then all other members of that business group must also join, and the lead entity must be a business-group member.

What the framework gives a group

A group-wide AML/CTF program and group-wide ML/TF risk assessment, developed by a single lead entity and applied across members
Services provided between group members are not designated services - intra-group transactions don't trigger AML/CTF obligations
Information sharing between members is permitted, including for CDD and SMR purposes, with reduced tipping-off risk within the group
Centralised compliance - any member (including non-reporting entities) can discharge obligations on behalf of others, though the entity whose obligation it is remains responsible

Lead entity accountabilities

In all configurations the lead entity carries specific legal accountabilities: developing the group-wide risk assessment, maintaining group-wide AML/CTF policies, ensuring members meet their obligations, and submitting (or delegating) the annual compliance report. If a member breaches a civil penalty provision, both that member and the lead entity are treated as having breached the Act. The Compliance Officer role is separate from the lead-entity designation - a single senior person can hold the CO role across the group. easyAML's onboarding includes a structure-mapping conversation to determine the right configuration. See AUSTRAC's Understanding Reporting Groups guidance.