Keddie Waller

Accountants need to get on the front foot and prepare for the sweeping reforms in the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime taking effect on 1 July 2026, the 2025 SMSF Association National Conference was told.

This was the message from Kath Bowler, General Manager of the law firm Holley Nethercote, and Keddie Waller, Policy Manager at the SMSF Association, delivered during their concurrent session titled Don’t Get Caught Out: AML/CTF Reforms Every Accountant and Adviser Must Know.

Common services such as setting up trusts, including SMSFs, handling client payments and facilitating debt or asset financing will be regulated for the first time, requiring accountants providing these services to enrol with AUSTRAC and comply with the new obligations.

Bowler and Waller told delegates that the 2026 launch of Tranche 2 of the AML/CTF regime – which are aimed at strengthening the regime to deter, detect and disrupt money laundering – would implement some of the most significant regulatory reforms in years.

“Importantly, it’s not about who you are, it’s about what you do.”

“Those AFS licensees who are currently caught by the AML/CTF regime and rely on the ‘item 54 designated services’ exemption,  may no longer be able to rely on the exemption and will be required to comply with all AML/CTF obligations.”

“Financial advisers who are eligible to continue operating under the exemption will be required to update their existing policies and procedures to comply with the amended requirements by 31 March 2026.

“No different to accountants, it means all financial advisers must reassess the services they provide against the new designated services.”

Bowler and Waller said it was imperative for accountants and advisers to identify how the new regulations will affect their businesses to determine if they will be regulated and what they need to do to ensure they are compliant with their obligations. This is important to mitigate business risks and avoid potential penalties for non-compliance.

“They need to begin making key decisions now so they can start taking steps to develop and implement an effective compliant framework tailored to their practice.

“It will be critical not to leave it until the last minute. If they provide a designated service before enrolling, there’s only 28 days to enrol and comply with a range of statutory obligations to avoid civil penalties. Don’t think this is a 2026 problem – there are practical steps to take now for a smoother transition to the new regime.”

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James Murphy

Midwinter has announced that it is partnering with Licensing for Accountants to provide compliance and advice technology for limited licence holders.

Licensing for Accountants (headed by CEO, Kath Bowler) supports accountants who are moving – or want to move – from compliance to advice. A key component of that support is the provision of access to advice templates and software that make the advice process easy and efficient. Midwinter has worked with Licensing for Accountants to create additional functionality and resources within its AdviceOS system to cater for both unlicensed accountants and licensed accountants with Limited Licences. The customised AdviceOS offers will be added to the suite of licensing solutions already available through Licensing for Accountants.

The new functionality contains a range of unique features to ensure the limited advice provided by accountants meets the requirements of the licensing regime. These include:

• A ‘Licensing Assessment Module’ to help accountants determine if the advice being provided requires licensing or not,
• An ‘Accountant Template Module’ which contains standard advice documents (FSGs, Fact Finds etc.) as well as a library of unlicensed templates, so accountants can document both licensed and unlicensed advice.

In addition, SOAs have been incorporated into Midwinter’s AdviceOS software, catering for simple advice to be produced in under an hour, with the resulting SOA typically containing no more than 10 pages. The software currently includes ten SOA template options, with more being added as required.

Licensing for Accountants CEO – Kath Bowler said “One of the biggest challenges facing all accountants, regardless of whether they entered the world of advice or not, was properly documenting their advice.

“For licensed accountants, this means finding a simple and easy way to prepare statements of advice, records of advice, fact finds etc.” Ms Bowler said.

“Both licensed and unlicensed accountants need templates to document the conversations they are having with clients in an unlicensed capacity, to confirm that the advice or information doesn’t require licensing.

“This is because both unlicensed and licensed accountants will not always be acting in a licensed capacity when they talk to their clients. For every client conversation, accountants need to be able to distinguish which hat they are wearing.”

Bowler said her search for solutions to these issues “involved a thorough examination of technology providers in the advice space, culminating in the partnership with Midwinter.

“They had one of the simplest software solutions to drive, an open architecture, and they were open to creating something unique to cater for the needs of accountants.” Ms Bowler said.

“We’re not trying to turn accountants into planners. We wanted to create a solution that was flexible, adaptable and would make licensing work for them.”

Executive Director of Midwinter – James Murphy, also expressed excitement about the partnership, saying “We’re delighted to be working with Kath and her business to provide this tailored solution. These additional modules within AdviceOS – custom made with the requirements of limited licence accountants in mind, have been welcomed not only by the accountants themselves, but also by many of their financial planning referral partners.

“For quite some time now, our financial adviser clients who work closely with accountants have expressed a desire for Midwinter to create a package that would allow both parties to work off the same system. Now, through Licensing for Accountants, we have been able to offer this.”

Ms Bowler stated that there had already been significant interest in the solution, with over 50 accountants attending a pilot webinar for the solution earlier today.

“The interest in the templates had been overwhelming – so much so that we have allowed for a pilot run while the solution is still in testing.

“The other area of interest for the unlicensed templates has been from full AFSL holders who have accountant referral partners. They have been looking to provide this to their referral partners as a value-add, as it makes those partners aware (from an independent source) when a piece of advice needs to be referred to them.”

Accountants are still being invited to register their interest in participating in the pilot run between the 1st and the 30th May 2016, with Go-Live for the solution scheduled to commence in mid-June.

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Liz Ward

Accountants are fast running out of time to become licensed, warns the SMSF Association’s Head of Education Services Liz Ward and Licensing for Accountants CEO Kath Bowler.

“July 1 next year might seem an eon away, but the reality is accountants who want to give financial planning and superannuation advice after this date need to start the process now.

“The first step is for accountants to decide whether they want to be part of the AFS licensing regime, and if the answer is ‘yes’ then you need to begin the training; it typically takes from a minimum of six months up to two years.”

Under the current system, accountants have an exemption under FOFA allowing them to give advice on setting up or winding up an SMSF. This exemption ends on 30 June 2016.

The SMSF Association has been working on this issue with Licensing for Accountants, an independent firm dedicated to guiding accountants through the licensing maze.

Ward and Bowler say: “From July 1, giving advice on setting or winding up an SMSF will be no different to advising on contributions, LRBAs, pensions or TTRs – if it gets into financial planning territory you will need a full or limited licence.

“If you aren’t licensed there is every possibility you will hold your business back, as well as potentially losing financial planning and superannuation revenue and clients to practitioners who are licensed.”

They say some accountants believe they can remain exempt as they only give tax advice.

“The question we’d pose to them is – are you really just giving tax advice?

“Remember, you will need to provide a disclaimer noting that you provide only tax advice, and that your clients must seek advice from a licensed financial adviser.

“But if you are taking other factors into account, such as when they can make contributions, rollover benefits, advice on the fund’s investments or commence an income stream then you will need a license.”

Ward says some accountants are working on the premise that the July 1 deadline will be extended.

“It’s worth remembering there was no extension granted to financial planners when their licensing regime was introduced. I suspect the official attitude will be that accountants have been given ample time to prepare, and it’s hard to argue with that.”

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AMP’s Head of SMSF Advice Kath Bowler said Saturday’s announcement of a Limited Australian Financial Services Licence (AFSL) for accountants strikes a balance between extending the advice accountants can offer, while keeping the licensing solution relatively simple and attainable. 

“The move represents an opportunity for accountants to provide a more comprehensive service to their clients and will allow their practices to thrive in the future,” Ms Bowler said. 

“This is also an opportunity for our existing aligned financial planners to explore and grow their relationships with accountants not looking to take on the responsibilities of licensing. 

“It’s important for accountants to be able to offer the support and expertise their clients are demanding which is why AMP’s Financial Advice Network established SMSF Advice in late 2011 to focus solely on the licensing needs of accountants and SMSF specialists. 

“We have developed a range of licensing and support options to enable accountants to customise the advice and services they provide to their clients.

 SMSF Advice offers three licensing options; basic, strategy and comprehensive. The Basic Option is a simple licensing option for accountants who want to continue to recommend SMSFs as well as provide basic superannuation advice to their clients. 

SMSF Advice’s Strategy Option is for accountants wanting to offer complex strategic advice in relation to SMSFs and non-super strategic advice.  The Comprehensive Option is a more traditional form of licensing that allows accountants to provide broad financial advice. 

Ms Bowler said SMSF Advice will review its licensing options in light of the Government’s announcement.  

“We are now in a position to build the final part of the SMSF Advice offer to support accountants wanting to obtain their own licence but needing support to do that. 

“At this early stage, we believe our existing range of licensing options, together with the new limited AFSL and referral opportunities with our aligned financial planners, provides accountants with choice to begin or progress down the path of their journey into financial planning,” Ms Bowler said.

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