Delayed CDD is a conditional legal pathway, not a label for overdue onboarding. Before using it, identify the applicable provision and exactly what it permits you to postpone. A short written decision should connect the legal basis, facts, remaining verification, controls and completion requirements. The general Australian-service pathway and special pathways, including real estate, have different limits; do not copy one deadline into every matter.
Record why the permission is available
AUSTRAC describes conditions including an essential need to avoid interrupting the ordinary course of business, low additional ML/TF risk and suitable policies to complete CDD and manage the delay. Mere inconvenience is insufficient. Identify the specific service, customer, rule and policy relied on. Explain which collection or verification steps are already complete and why the remaining work falls within that permission, rather than leaving the whole customer file unassessed.
Translate the rule into a controlled work boundary
Under the general Australian-service rule, specified verification may be delayed, but initial CDD must finish as soon as reasonably practicable, within the applicable 20-business-day outer limit and before specified transfer or asset-availability events. Check the precise rule for the matter; special pathways differ. Record the earliest applicable completion point and the acts staff must not undertake before it. Treat a planned transaction date as a live control, not simply a calendar reminder.
Assign a completion owner and escalation time
List the remaining requests, permitted evidence methods, responsible person and internal escalation date. Set the internal review early enough to act before the legal boundary, without representing that earlier date as a statutory deadline. If information arrives with a material inconsistency, reconsider the original low-additional-risk conclusion. A delay decision made on one set of facts should not carry on silently after the facts supporting it have changed.
Keep the complete decision history
Consider a time-critical service where the customer has supplied information but a permitted verification step is outstanding. The record should show why work could begin, which steps remained restricted and what later completed the verification. If completion becomes unlikely, escalate the actual position and decide whether to stop or take another lawful course. Do not reset the commencement date, backdate approval or replace the original decision with a later clean-looking version.
Official sources
Confirm the current rules against these primary sources, last checked .
Questions
Is 20 business days available for every designated service?
No. Identify the applicable pathway. Special service rules, earlier transaction events and the reasonably-practicable requirement can produce a different completion boundary.
Can information collection always be postponed?
No. The provision may permit only particular verification or CDD steps to be delayed. Identify what must already be established before starting.
Does internal approval make a delay lawful?
Approval records the practice's decision; it cannot replace the statutory conditions or expand what the relevant provision permits.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
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