Trust Account Audit Checklist for Real Estate Agencies

Real estate agencies that hold rent, sale deposits and other client money in a trust account must have that account audited by an independent, approved auditor every year. The rules differ by state: the audit period, the deadline, who can audit and what happens when you're late are all set by each state's legislation and regulator. This checklist covers the documents, reconciliations and tests an auditor typically works through, and flags where the states differ, so you can prepare properly or, if you're an investor, judge whether your property manager runs a tight ship.

Last verified 16 October 2026 against official sources. General information only, not legal advice. Check your own state regulator before relying on any date or threshold.

Why trust account audits exist

Agents handle money that belongs to other people: landlords' rent, buyers' deposits and similar funds. State laws require that money to be kept in a dedicated trust account, separate from the agency's own operating money, and to be independently checked each year.

The auditor's job is to give assurance that the agency has kept proper records and handled trust money as the law requires. In practice the audit looks at:

• Monthly reconciliations that tie the trust cash book, the client ledgers and the bank statement together.
• Client ledgers that show what is owed to each landlord or other trust creditor.
• Receipts and payments, including the authority behind each withdrawal.
• Compliance with the state's rules on banking, record keeping and timing.

An audit report can be qualified or can flag breaches when the auditor finds problems. Regulators take that seriously, and in several states a failure to lodge the audit on time is an offence in its own right.

How the states differ

There is no single national audit deadline. The verified examples below show how much the rules vary.

• NSW: the audit period is the year ending 30 June, and the auditor's report is due within three months of the end of the period and no later than 30 September. The auditor submits it online through NSW Fair Trading's Auditor's Report Online portal, but the licensee remains responsible for making sure it is lodged on time. NSW Fair Trading says it could issue a $550 fine to an individual or $1,100 to a corporation for a late audit, and a licence may not be renewable until the report is lodged.
• Victoria: trust accounts must be audited each year for the period 1 July to 30 June, with the audit and report completed within three months after 30 June. The agent must lodge a copy of the report in myCAV within 10 business days of receiving it from the auditor. Failing to do so is an offence carrying a penalty of up to 120 penalty units, and the licensing authority may suspend a licence.
• Queensland: the trust account must be audited every year over a 12-month audit period that ends on the last day of a month. The audit report (or statutory declaration) must be lodged within four months after the end of the audit period. The licensee is responsible for lodging, although the auditor can lodge on their behalf. Late lodgement can lead to a fine, conviction, or licence suspension or cancellation. Queensland's trust rules sit in the Agents Financial Administration Act 2014.
• Western Australia: recent Consumer Protection bulletins describe an audit period of 1 January to 31 December with the auditor lodging the report by 5pm on 31 March. Agents who held no trust money can lodge a declaration instead. Earlier bulletins used a 30 June year end, so confirm the current cycle with Consumer Protection.
• Other states and territories: South Australia, Tasmania and the ACT also have their own audit rules. This post does not state them because we have not confirmed each one against the legislation. Check your regulator.

The timeline that keeps agencies out of trouble

Because the periods differ, count back from your own state's audit period end rather than from a fixed date. The rhythm below suits most agencies.

Eight weeks out

Confirm your auditor's engagement. Make sure your auditor is eligible: in Victoria, for example, the auditor must be an approved practising public accountant and cannot be an estate agent or their employee, or have been an employee or partner of that agent within the previous two years. NSW has a similar two-year independence test. Review the previous year's findings and confirm every earlier month is reconciled.

Six weeks out

Close any open reconciliations from the prior period. Chase unresolved differences back to their source now rather than during fieldwork.

Four weeks out

Run the final month's reconciliations and print the trust ledger and trial balance for the period end.

Two weeks out

Collate authorities for payments out of the trust account, and download the bank statements for every month of the audit period.

One week out

Assemble the audit file: reconciliations, ledgers, management agreements, receipts and payment authorities. Brief whoever will answer the auditor's questions.

Audit week

Be available. Queensland's guidance notes that auditors must make at least one unannounced examination in an audit period of over six months, so keep records current all year rather than tidying up at the end.

Core documents your auditor will request

Pack these into a single folder, digital or physical, before fieldwork starts.

• Bank statements for each trust account, every month of the audit period.
• Monthly reconciliations of the trust cash book, the client ledgers and the bank statement, signed off by the person responsible. Queensland's auditor report requires a copy of the reconciliation and a statement of whether each month of the audit period was reconciled.
• A listing of trust creditors, with each client's name and the amount owed. Queensland auditors must state whether an analysis of each trust creditor's name and amount owed was made.
• The trust ledger and trial balance, exported from your property management software.
• Signed management agreements for each landlord whose money passed through trust.
• Payment authorities such as invoices and written client instructions for each withdrawal.
• Receipt records, including the receipt register where you issue printed receipts.
• Evidence of rental bond lodgement with the state bond authority (more on this below).

If you use cloud property management software, most of these export as CSV or PDF. Expect the auditor to compare the software's trust reports against the bank's transaction list.

The monthly reconciliation

Monthly reconciliation is the heartbeat of trust accounting. Every month the trust cash book, the client ledgers and the bank statement must agree. The deadline depends on the state:

• Queensland: the Office of Fair Trading says the reconciliation must be completed within 5 days after the end of the month.
• Victoria: reconciliation statements must be verified by the principal agent or officer in effective control within 14 days after month-end.
• Other states: check your regulator for the deadline. We have not confirmed the NSW and WA figures against the primary legislation, so this post does not state them.

The basic mechanics are the same everywhere. Start with the bank statement balance, add deposits recorded but not yet banked, subtract payments recorded but not yet cleared, and the result should equal the trust cash book balance. That balance should in turn equal the total of the client ledgers.

When there is a difference, auditors trace it back to the month it first appeared. Common causes include:

• Rent received into the operating account by mistake instead of trust.
• A duplicate payment batch, so a landlord is paid twice.
• A manual journal in your software that doesn't match any bank transaction.
• A receipt posted to the wrong landlord ledger.

There is no single national dollar threshold for what counts as a material difference. Don't rely on rules of thumb such as "$500 or 1%". Treat every unexplained difference as something to clear before the audit.

Receipts and banking

Auditors usually sample receipts and check that the source document exists, that the amount matches the bank deposit and the ledger, that the money went to the right client's ledger, and that it was banked on time.

Banking deadlines are set by each state:

• Victoria: trust money must be paid into the trust account by the next business day after you receive it, or the third business day if your agency is more than 16 kilometres from an authorised financial institution. Trust transactions must also be recorded in your accounting records by the end of the next business day.
• Queensland: the OFT says received trust money must be banked into the trust account before the end of the first business day.

Whatever your state, rent that lands in the operating account and is moved to trust later is a classic deficiency. Check your bank feed and payment settings so tenant rent routes to the trust account from the start.

Receipt rules also apply. In Victoria you must provide a receipt for trust money received and keep a duplicate for seven years, although a receipt isn't required for a cheque or EFT that you recorded electronically if the payer didn't ask for one.

Payments from trust

Auditors also sample payments. For each one they expect to see written authority and a correct amount.

• Landlord disbursements: the management agreement authorising fees and net payments.
• Contractor payments: the invoice and the landlord's authority to pay it from their funds.
• Fees: the amount deducted matches the agreement.

Queensland's OFT states that written client authority is needed for withdrawals, that you must distribute trust money directly from the trust account, and that it is illegal to transfer money to recipients via a general account. Queensland also requires trust records to be kept for 5 years, while Victoria requires at least seven. Check your state's retention period.

Watch for these red flags:

• Round-number payments with no invoice.
• Payments to a business connected to the licensee without written disclosure and consent.
• Payments that push a landlord's ledger negative, which means other clients' money is funding the payment.

On GST: whether GST applies to a given payment depends on the supply and on your agency's registration, and cannot be reduced to a blanket rule. Raise it with your accountant and see the ATO's guidance on property management and GST.

Rental bonds are not held in the agency trust account

A common misconception is that agencies hold tenant bonds in their own trust account and work out interest on them. In the states we checked, that's not how bonds work. Bonds are lodged with a state authority:

• NSW: held by NSW Fair Trading through Rental Bonds Online.
• Victoria: lodged with the Residential Tenancies Bond Authority (RTBA), which holds the bond in trust until the end of the rental agreement. Consumer Affairs Victoria says the rental provider must lodge it within 14 days of receiving it.
• Queensland: the lessor or agent must pay the bond to the Residential Tenancies Authority (RTA) within 10 days of receiving it, and failing to do so is an offence.
• Western Australia: bonds go to the Bond Administrator at Consumer Protection.

The auditor's concern is therefore usually timely lodgement, not interest calculations. We could not verify bond lodgement rules for South Australia, Tasmania or the ACT here, so check your regulator.

Interest on trust accounts

Interest on agency trust accounts is also not something the agency calculates and remits. In NSW, for instance, authorised deposit-taking institutions must calculate interest on agents' trust accounts and pay a prescribed proportion to the Property Services Statutory Interest Account. Check how your state treats interest on general trust accounts.

Common deficiencies and how to fix them early

Late or missing reconciliations

Complete the outstanding reconciliations immediately and document why they were late. Going forward, diarise the month-end deadline for your state.

Unexplained differences

Trace each one to its source, such as a bank fee, duplicate payment or posting error, and correct it with a properly authorised journal. Review reconciliations monthly rather than at year-end.

Missing management agreement or payment authority

Obtain a signed copy or written authority now, and change your workflow so no payment batch is released without one.

Rent banked into the wrong account

Move it to trust, fix the payment instructions, and keep a note of the correction.

Late audit lodgement

This is the one that attracts penalties on its own. Know your state's deadline, confirm your auditor has everything they need, and ask early if an extension is possible. In Western Australia, an extension must be requested by the auditor and approved before the deadline.

A short monthly self-check helps. After month-end, have the licensee review the reconciliation and test a handful of receipts and payments. Catching problems while they're fresh is far cheaper than finding them during fieldwork.

Frequently asked questions

Do all Australian agencies need an annual trust account audit?

Agencies that hold trust money are generally audited every year, but the rules differ by state. NSW audits cover the year to 30 June, lodged by 30 September. Victoria requires completion within three months after 30 June. Queensland requires lodgement four months after the audit period. Western Australia currently uses a calendar year with a 31 March deadline.

Are tenant bonds held in the agency's trust account?

Generally no. In NSW, Victoria, Queensland and Western Australia, bonds are lodged with a state authority rather than kept in the agency's trust account. Queensland requires lodgement within 10 days of receipt, and Victoria requires it within 14 days. Check your own state regulator for the deadline that applies to you.

What happens if an agency lodges its audit late?

Consequences vary by state. NSW Fair Trading could issue a $550 fine to an individual or $1,100 to a corporation, and licence renewal may be blocked. In Victoria, late lodgement is an offence carrying up to 120 penalty units. Queensland can fine, convict, or suspend or cancel a licence. Western Australia may issue infringement notices or prosecute.

How soon must the monthly reconciliation be done?

It depends on the state. Queensland's Office of Fair Trading requires the reconciliation within 5 days after the end of the month. In Victoria, the principal agent or officer in effective control must verify reconciliation statements within 14 days after month-end. Other states set their own deadlines, so confirm yours with your regulator.

What this means for your portfolio

If you own investment property through a family trust, company or SMSF, you rely on your property manager's trust account to receive rent, pay contractors and send the net income to you. A qualified audit, a late lodgement or a licence problem at the agency can delay payments and create real friction for your cash flow.

When evaluating property managers, ask:

• "When was your last trust account audit, and did it raise any issues?"
• "How soon after month-end do you complete your trust reconciliation?"
• "Can I see a sample month-end statement showing what is held for my property?"

An agency that can answer these quickly and clearly is usually managing your money properly.

InvestorJoint's rental cashflow calculator models the investor side of a property, and our family trust guide and SMSF guide explain how ownership structures interact with property management. InvestorJoint can also help you keep an investor-side record of the rent, invoices and fees your agent reports, so you can compare it against your own bank feed and spot late rent or fee variances before tax time. If you're weighing up structures, the trust vs. personal calculator, negative gearing calculator and depreciation calculator are good places to start.

If you're preparing for your own trust account audit, treat this as a working checklist and confirm every date with your state regulator. If you're the investor, treat it as a diligence framework for choosing a property manager.