The planner: Item 54 and its exemptions

Item 54 of Table 1 in section 6 of the AML/CTF Act covers an AFS licensee that makes arrangements for a person to receive another designated service. A planner who helps a client complete an application, negotiates with a product issuer, or coordinates the steps for a product to be provided is typically “making arrangements”.

The regime treats this as lower risk, because the business receiving the referral is itself regulated. Where Item 54 is the only designated service a licensee provides, the reformed Act (sections 26T, 30(10), 39(7), 44(6) and 47(5)) removes a substantial part of the full program.

The obligation that remains front and centre is initial CDD. The planner must still collect, verify and screen before the arrangement is made. Where planners work through authorised representatives, the licensee is the reporting entity and its representatives follow the licensee's program.

The exemptions are conditional. If the licensee provides any other designated service, including a Table 6 professional service, they fall away and the full program applies.

The accountant: Table 6 and the full program

When the accountant accepts the client's instructions and starts drafting the trust deed or company documents, they are providing a Table 6 designated service (Item 6: creating or restructuring a body corporate or legal arrangement). Table 6 obligations apply from 1 July 2026.

AUSTRAC uses this exact scenario as a worked example. A financial adviser recommends a structure, introduces the client to an accountant and helps with rollover forms: that is Item 54. The accountant who drafts and facilitates execution of the trust deed directly advances its creation: that is Table 6. The adviser influences the outcome; the accountant delivers it.

The accountant has no Item 54-style relief. They need the full program: a compliance officer, governing body oversight, ongoing CDD, staff training, independent evaluation and annual compliance reporting.

Their CDD scope is also wider. For item 6, the customer is the person giving instructions plus:

•         for a new company, its proposed beneficial owners and directors

•         for a new express trust, its proposed trustee, settlor and beneficiaries

So the accountant may need to verify a spouse, adult children named as beneficiaries, and a corporate trustee's directors, in addition to the person the planner originally saw.

The friction: one customer, asked twice

From the customer's side, the two regimes are invisible. They have one journey: advice, then structure. Yet two reporting entities must each be satisfied about who they are.

The planner runs initial CDD under policies scoped only to that step. A few weeks later, the accountant runs CDD under a full program, with its own risk assessment, its own verification standards and a wider set of people to check. Each firm is right to apply its own rules. The customer, however, experiences it as the same request made twice: find your passport again, take another selfie, re-enter the same address.

That repetition has real costs:

•         Drop-off between referral and engagement, at precisely the point the accountant is trying to win the work

•         A poorer impression of both firms, who are often long-standing referral partners

•         More manual handling of identity documents, with more copies held in more places

•         Delay to the structure being set up, and so to the advice being implemented

How VerifiMe and VerifiOnce change the journey

With VerifiMe and VerifiOnce, the customer completes their identity uplift once, and each firm still runs its own CDD under its own rules. Two assessments, two rule sets, one uplift.

1.       The planner verifies. The planner sends a VerifiMe link. The customer completes verification once: documents checked, biometrics matched, screening run. The planner's initial CDD is satisfied under its Item 54 policies.

2.       The customer holds a reusable credential. Through VerifiOnce, the verified result becomes a credential the customer controls, rather than a file locked inside the planner's system.

3.       The customer chooses to share. When referred to the accountant, the customer consents to share their credential. Nothing moves without that consent.

4.       The accountant runs its own CDD. The shared data arrives in the accountant's own VerifiMe workflow. The accountant's rules engine applies its own risk assessment, verification standards and screening, and flags anything its program needs that the credential does not cover.

5.       The accountant adds the wider parties. Proposed directors, trustees and beneficiaries are invited through the same platform, each verifying once and holding their own credential for future use.

6.       Ongoing obligations sit with the accountant. Ongoing CDD and monitoring, which the planner is exempt from, run within the accountant's program from day one.

The value is not that one firm's work replaces the other's work. It is that the customer's effort is captured once and put to work under each firm's own rules. For the accountant, a referral arrives ready to onboard. For the planner, the hand-off reflects well on them. For the customer, it simply feels like one joined-up experience.

What this is, and what it is not

VerifiOnce supports each reporting entity's own CDD. It is not reliance under sections 37A or 38 of the AML/CTF Act, and it does not move any obligation from one firm to another.

•         Each firm remains accountable. The accountant is not relying on the planner's CDD. It receives verified data with the customer's consent and applies its own program to it.

•         Different rules still apply. Where the accountant's program calls for more than the credential holds, such as a further document or enhanced CDD for a higher-risk customer, the platform requests it. The customer is asked only for what is genuinely new.

•         Watch the cliff edge. A planning practice that also drafts trust deeds, sets up companies or manages client money under a discretionary authority is providing a Table 6 service. Its Item 54 exemptions fall away across the business. Dual-hatted practices should map their services carefully before relying on the lighter regime.

One customer, one uplift

The reforms have drawn a line between the planner who arranges and the accountant who acts. That line is right for regulators, but customers should not have to feel it. With VerifiMe and VerifiOnce, planners and accountants can each meet their own obligations while their shared client verifies once.

If you are a planning practice or accounting firm working through referral relationships ahead of, or since, 1 July 2026, we would be glad to show you how this works in practice. Do get in touch with the VerifiMe team through hello@verifime.com.

Sources

•         AUSTRAC,       Exemptions from AML/CTF obligations for businesses providing only item 54 designated services

•         AUSTRAC,       Professional services (Reform)

This article is general information, not legal advice. Firms should consider their own circumstances and obtain advice where needed.