Firms are giving up registered office services, and what that means for their clients

Since 1 July 2026, providing a registered office address or principal place of business address for a company or other body corporate or legal arrangement has been a designated service under Australia’s AML/CTF regime. A lot of accounting and legal practices have looked at what that means in practice and decided they no longer want to be in the business of holding client addresses. That is a defensible commercial decision. The problem is what happens to the clients who were relying on it.

Most firms did not think of it as a service at all. A client incorporated a company, had no premises of their own or did not want their home address on a public register, and the practice address went on the ASIC record. No engagement letter, no fee, no file note. Over twenty years that quietly accumulates into thirty or eighty entities registered at the firm’s office. Tranche 2 turned that accumulation into scope.

The obligation itself is not exotic, but it is continuing. Before providing the service you have to identify and verify the customer, understand its ownership and control including beneficial owners, screen appropriately and assess risk. The service then has to sit inside your firm’s risk assessment and AML/CTF policies, records have to be kept, and because the address is provided continuously rather than once, ongoing customer due diligence runs for as long as the address is held. That is the part that separates it from a company registration. A formation is a single designated service with a defined end. A registered office is a designated service you are still providing five years later, for a client whose circumstances you may no longer be across.

Set the AML position aside for a moment, because most firms already had good reasons to get out of this. Mail arrives for entities the firm stopped acting for years ago. Process servers attend the practice reception. Debt collectors write to the registered office. A client leaves, never changes the address, and the firm remains on the public record as the place where documents can be served on a company it has nothing to do with. Under section 142 the occupier has to consent to the address being used, and a consent given in 2014 by a partner who has since retired is not a comfortable thing to rely on.

So firms are making one of three choices. The first is to keep providing the service, bring it properly inside the AML/CTF program, document the consent, and start charging for it. That is legitimate, and a handful of larger practices have gone that way. The second is to write to every client and tell them to nominate their own address. The third is to move the addresses to a provider whose business this is.

The second option is the one that causes damage, and it is the most common because it looks like the cheapest. Telling a sole director operating from a spare bedroom to put their own address on the ASIC record puts their home address on a public search that anyone can run for a few dollars. It is searchable by former partners, disgruntled customers, and anyone with a grievance against the company. Some clients have no commercial premises at all and no realistic alternative. A letter that solves the firm’s compliance problem by creating a personal safety problem for the client is not a good outcome, and it is usually remembered.

The third option is the one we exist for, and the shape of it matters more than firms expect. The client contracts with us for the address and we provide it, which makes us the reporting entity for that service. Your firm refers the client, stays the adviser, and stops being the address of record. We are the occupier of our Unley premises, so we give the occupier’s consent in our own name and keep it on file. We lodge the change of registered office with ASIC on Form 484 for each entity, which can be done as a single batch rather than one at a time. Mail and ASIC notices are opened, scanned and emailed the day they arrive, routed to your firm, to the client, or to both, depending on how your firm prefers to work.

Firms often ask whether they can white label this and bill it under their own brand. Commercially, yes, and we will supply on that basis. But it is worth thinking about before you ask for it. The further the arrangement moves towards your firm contracting with the client to provide the address, with us as your supplier, the more it looks like your firm is the one providing the designated service. That is the position most firms are trying to get out of, so the branding and the compliance distance pull against each other. It is also worth knowing that the address itself is fairly anonymous already: an ASIC search returns a street address, not the name of whoever operates it, so a referral arrangement gives a firm most of what it wanted from white labelling without the scope question.

On the AML side, the obligation follows the entity providing the designated service. Once we provide the address, we are the reporting entity for that service and we carry the customer due diligence, the ongoing monitoring and the records that go with it. Your firm still needs its own program for the designated services it continues to provide directly, and moving an address does not erase records you were already required to keep. What it does is stop the list of continuing designated services in your firm growing every time a client needs somewhere to be registered.

On identification, the default is that we do the work, because we are the reporting entity for the service. Before the address goes live we identify and verify the client entity and its beneficial owners. No arrangement removes that step, so it is worth telling the client to expect it, and a one-off screening fee applies where we perform the due diligence. The one variation is for a client your firm has already verified and would rather was not asked twice. There a written reliance arrangement, set up once in the client portal, lets us rely on your due diligence instead. That suits firms that still act for the client on other matters. It is not the right answer for a firm whose reason for moving the addresses was to stop carrying customer due diligence at all.

Sequencing matters if you have a book of these. Start by exporting every entity where the practice address sits as the registered office, then split that list into clients you still act for and clients you do not. The second group is the more urgent one, because those are the entities generating mail for companies you have no authority over, and it is the list most firms have never actually looked at. For current clients, decide whether the cost is billed on or absorbed before you write to anyone. Our address services run from $790 a year per entity, with volume rates once a firm is placing more than a handful, so the number you need for that conversation is easy to get.

One boundary worth stating plainly. We are not AML consultants. We do not prepare, review or sign off your firm’s risk assessment or AML/CTF policies, and nothing here is AML advice or a legal opinion on your obligations. For that, work with an AML specialist or your professional body, and start with AUSTRAC’s own guidance and its starter kit for accountants, which are free. What we can do is take the addresses off your register and look after the clients sitting behind them.