AML/CFT annual reporting: why accurate information matters
29 October 2026
DIA recognises that completing annual AML/CFT reports takes time and effort, particularly for businesses managing their compliance obligations alongside their day-to-day operations. We appreciate the work reporting entities put into providing this information.
Annual reporting is more than a tick-box exercise. Accurate and complete reporting benefits both individual businesses and the wider AML/CFT system. It helps DIA better understand each reporting entity’s risk profile, support a proportionate approach to supervision and identify where further guidance or engagement may be useful.
In this article, we share some insights from the latest annual reporting period and explain how reporting entities can help ensure the information they provide supports an effective, risk-based approach to AML/CFT supervision.
Annual reporting at a glance
DIA received annual reports from approximately 89% of the reporting entities recorded as required to submit for the latest reporting period.
This figure needs to be considered in context. DIA’s records may include businesses that have ceased trading or no longer undertake activities covered by the AML/CFT Act but have not yet been formally removed from the system. However, there are a proportion of reporting entities that fail to submit their reports when required.
DIA is continuing its work to ensure that all reporting entities are identified and our records are accurate. Our recent project in the real estate agent sector supported by the Real Estate Authority is a good example of how we are working with industry partners to support this. This identified a number of real estate agents that were reporting entities but had not submitted annual reports.
An ongoing focus will be to strengthen our relationships with industry bodies and professional associations, working together to identify businesses that are reporting entities and those that may no longer be, and to improve awareness of AML/CFT obligations.
The latest results highlight a strong response from newly captured reporting entities and sectors transitioning from the Financial Markets Authority and Reserve Bank of New Zealand, with these businesses demonstrating strong levels of engagement and compliance with annual reporting requirements. Reporting entities that belong to a designated business group also generally have higher submission rates than standalone businesses.
These findings provide useful context for understanding annual reporting performance, while highlighting opportunities to improve reporting processes and support businesses to meet their obligations.
How DIA uses annual reporting information
Annual reports require information about reporting entities’ business activities, customers, products and services, risk assessments and AML/CFT programmes.
DIA uses this information alongside other sources to understand risk across the sectors it supervises and inform decisions about where supervisory attention is most needed.
For example, annual reporting can help identify changes that may warrant further consideration, such as significant increases in higher-risk customers, trusts, foreign customers or politically exposed persons (PEPs); increased use of non-face-to-face onboarding; expansion into higher-risk jurisdictions; or material changes in products, services, customer numbers or transaction volumes.
This information can contribute to decisions about whether an entity or sector may benefit from further engagement, a desk-based review, an on-site inspection or a thematic review. It can also help DIA identify broader trends that may inform guidance and education for particular sectors.
Information that differs significantly from sector trends or an entity’s previous reporting may prompt further enquiries to understand the reasons for those differences. An unusual result does not necessarily mean something is wrong, but reliable information helps DIA assess the circumstances and determine an appropriate response.
Accurate and complete reporting benefits both reporting entities and the wider AML/CFT system. It helps DIA make better-informed decisions, understand each business’s risk profile and direct supervisory attention where it is most needed. In turn, this supports a proportionate approach to supervision and helps reduce unnecessary follow-up where a business’s risks are well understood.
Getting annual reports right
Reporting entities play an important role in ensuring the information available to DIA is reliable and useful.
When completing an annual report, businesses should take care to:
- Provide accurate information that reflects their current business activities, customers, products, services and risk profile.
- Complete all relevant fields and ensure responses are appropriate to their business, rather than leaving relevant information incomplete.
- Review their responses before submitting to check that the information is consistent and accurately reflects their circumstances.
- Keep their details up to date and advise DIA if they cease trading or stop undertaking activities covered by the AML/CFT Act.
Taking the time to complete an annual report accurately helps DIA build a clearer picture of the risks reporting entities face. It also helps ensure supervisory decisions are informed by reliable information, rather than incomplete or outdated records.
Support for reporting entities
DIA has seen an increase in reporting entities contacting the Department compared with the previous year. This was expected following the transition to a single AML/CFT supervisor on 1 July 2026 and the requirement for all reporting entities to submit annual reports through AML Online.
Most enquiries have related to access permissions, technical issues or configuring the correct reporting entity, compliance officer and delegate roles. Other enquiries have involved businesses advising that they have ceased trading or no longer undertake captured activities and seeking to be removed from DIA’s records.
These interactions highlight some of the practical challenges businesses can face when managing their AML/CFT obligations, particularly when accessing and using online systems.
DIA encourages reporting entities experiencing access or configuration issues to seek assistance early, rather than risk missing reporting deadlines. Businesses that have ceased trading or stopped undertaking captured activities should also contact DIA so their status can be reviewed and records updated.
New reporting entities should notify DIA so they can be added to its records and receive reminders about annual reporting deadlines and other supervisory information. This helps ensure DIA has an accurate picture of the reporting entity population and avoids the need for DIA to identify them through its own monitoring.
DIA recognises that smaller businesses, including sole traders, may need support to manage their AML/CFT obligations. If you need further information or assistance, visit DIA’s AML/CFT guidance and resources or email amlcft@dia.govt.nz with your questions. Industry bodies and professional associations can also help by sharing guidance with their members and directing them to the right information.
Working together to strengthen the AML/CFT system
Accurate annual reporting is an important part of a broader, risk-based approach to AML/CFT supervision. It helps DIA identify and understand the population it supervises, identify potential areas of concern and respond proportionately to the risks businesses present.
Reporting entities can contribute by providing complete and accurate information, keeping their details current and seeking help when they encounter difficulties. Industry bodies can also play an important role by reminding members of their obligations and helping businesses access relevant guidance.
By working together to improve the quality of information available, DIA and reporting entities can support more effective supervision, reduce unnecessary regulatory burden and help make it easier to do business and harder to commit crime.
