# Who regulates property technology in Queensland: a map of the watchdogs

No single body oversees property technology in Queensland. Nine state and federal regulators each hold a piece: here is what each one covers, and where the pieces meet.

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A Queensland home can now be advertised on a portal, inspected through a booking app, applied for on a rental platform, contracted with electronic signatures, settled across an electronic network and paid for without a single cheque. Each of those steps runs on software, and each piece of software sits under somebody's rules. The difficulty is that there is no "property technology regulator" to ask. Nobody licenses a proptech company as such.

What exists instead is a patchwork. Queensland regulates the people who sell and manage property, the land register and the tenancy relationship. The Commonwealth regulates privacy, financial products, money laundering controls, competition and consumer protection. A national council of land registrars writes the model rules for electronic settlement. A product can fall under four of these bodies at once, or, occasionally, under none of them directly.

This guide maps the regulators that matter, what law each one administers, and the kind of digital activity that brings a business or a person into its field. It describes the position as it stands in early June 2026, including one large change already legislated to start on 1 July 2026.

<div class="keyfacts">
<div><b>9</b><span>regulators and councils covered in this map</span></div>
<div><b>4</b><span>of them are Queensland bodies</span></div>
<div><b>1 July 2026</b><span>start of anti-money-laundering duties for agents</span></div>
</div>
<p class="src">Count of the bodies described in this guide; the start date is the one published by AUSTRAC for real estate, legal and conveyancing services.</p>

## Why there is no single regulator

Regulation in Australia follows activities, not industries. The law asks what a business does: does it act as an agent in a sale, hold money on trust, lodge a document in the land register, collect personal information, offer an investment, extend credit? The technology used to do it is mostly irrelevant. An agent who lists a house through an app is still an agent. A scheme that pools investors' money into a house is still an investment scheme, whether the units are recorded on paper or on a distributed ledger.

The Constitution adds a second split. Land law, tenancy law and the licensing of occupations belong to the states, which is why Queensland has its own Property Occupations Act, its own Land Title Act and its own tenancy statute. Corporations, banking, privacy, telecommunications and trade practices are largely Commonwealth matters. Electronic conveyancing sits between the two: each state and territory has passed the same national law, and their registrars coordinate through a council.

The practical result is that a new product is rarely "unregulated", even when no rule mentions it by name. It is usually caught by an older rule written for the activity it automates. The table below gives the short version; the sections that follow give the detail.

<figure class="fig"><figcaption><b>The regulators at a glance</b><span>Position at June 2026</span></figcaption>
<div class="scroll"><table class="tbl">
<thead><tr><th>Body</th><th>Level</th><th>Main law</th><th>What brings technology under it</th></tr></thead>
<tbody>
<tr><td>Office of Fair Trading</td><td>Queensland</td><td>Property Occupations Act 2014</td><td>Acting as an agent, auctioneer or property manager; trust money; advertising</td></tr>
<tr><td>Titles Queensland and the Registrar of Titles</td><td>Queensland</td><td>Land Title Act 1994</td><td>Lodging anything in the land register; running a settlement network</td></tr>
<tr><td>ARNECC</td><td>National council</td><td>Electronic Conveyancing National Law</td><td>Model rules for settlement networks and their users</td></tr>
<tr><td>Residential Tenancies Authority</td><td>Queensland</td><td>Residential Tenancies and Rooming Accommodation Act 2008</td><td>Rental applications, rent payment methods, bonds, tenant data</td></tr>
<tr><td>QBCC</td><td>Queensland</td><td>Queensland Building and Construction Commission Act 1991</td><td>Building work, licences and home warranty insurance</td></tr>
<tr><td>AUSTRAC</td><td>Commonwealth</td><td>Anti-Money Laundering and Counter-Terrorism Financing Act 2006</td><td>Brokering sales, conveyancing, moving value, virtual assets</td></tr>
<tr><td>OAIC</td><td>Commonwealth</td><td>Privacy Act 1988</td><td>Collecting, storing and sharing personal information</td></tr>
<tr><td>ASIC</td><td>Commonwealth</td><td>Corporations Act 2001 and the national credit law</td><td>Investment products, fractional ownership, lending</td></tr>
<tr><td>ACCC</td><td>Commonwealth</td><td>Competition and Consumer Act 2010</td><td>Misleading claims, unfair terms, market power, scams</td></tr>
</tbody>
</table></div></figure>

## The Office of Fair Trading: people, licences and trust money

The Office of Fair Trading (OFT) is the Queensland regulator closest to the daily business of selling and managing property. It administers the Property Occupations Act 2014, which requires a licence or registration certificate for anyone who, for reward, sells, buys, exchanges or lets property for others, collects rent or conducts auctions. It also administers the Agents Financial Administration Act 2014, which sets the rules for trust accounts and the claim fund that compensates people who lose money through an agent's wrongdoing.

Neither Act is written around technology, and that is the point. A website or app that merely carries advertisements does not need a property licence. A business that negotiates a sale, introduces a buyer for a commission or collects rent on behalf of an owner is performing the licensed activity, whatever interface it uses. The OFT's public licence register is the tool for checking which side of that line a business sits on.

Three parts of the OFT's remit touch digital dealings directly. The first is advertising: the Property Occupations Act and the Australian Consumer Law, which the OFT enforces in Queensland alongside the national regulator, both prohibit false or misleading representations about property, and they apply to a listing on a portal exactly as they do to a signboard. The second is trust money. Deposits and rent received by an agent must go into a trust account kept under the Agents Financial Administration Act, and software that moves or reconciles that money does not change who is accountable for it: the licensee is. The third is records. Appointment forms, trust ledgers and audit reports may be kept and signed electronically where the law allows, but they must be producible to an OFT inspector on request.

The OFT can investigate, issue infringement notices, start proceedings in the Queensland Civil and Administrative Tribunal for disciplinary action, and prosecute unlicensed trading. What it does not do is approve software, certify platforms or endorse products.

## Titles Queensland and the Registrar of Titles

Ownership of land in Queensland is created by registration. The freehold land register is kept under the Land Title Act 1994 by the Registrar of Titles, a statutory officer, and operated day to day by Titles Queensland. Anything that changes the register, such as a transfer, a mortgage, a release, a caveat or a priority notice, has to be lodged in a form the Registrar accepts.

That makes the Registrar the gatekeeper for the most heavily regulated piece of property technology in the state: the electronic lodgment network. According to Titles Queensland, e-conveyancing has been mandatory since 20 February 2023 under the Land Title Regulation 2022 for a set of common instruments, including the transfer, the release of mortgage, the national mortgage form, caveats and priority notices, when they are lodged by solicitors, financial institutions and other industry professionals. Exemptions exist, among them a party who is an unrepresented individual and circumstances where the system cannot handle the dealing.

The Registrar's powers over those networks come from a separate statute, the Electronic Conveyancing National Law as applied in Queensland by a 2013 Act. Under it the Registrar approves each electronic lodgment network operator, sets the operating requirements the operator must meet and the participation rules its subscribers must follow, and may waive compliance in particular cases. Titles Queensland lists two approved operators, PEXA and Sympli.

For everyone else in the property technology field, the Registrar matters in a quieter way. A product that produces a document meant for registration has to produce it in the Registrar's form and with the Registrar's execution and witnessing requirements, and those requirements are set out in the Land Title Practice Manual. Software cannot contract out of them.

## ARNECC: the national council behind the settlement rules

The Australian Registrars' National Electronic Conveyancing Council, known as ARNECC, is often described as the regulator of e-conveyancing. Strictly, it is not a regulator at all. According to its own website, the council was established in 2011 under an intergovernmental agreement among all states and territories to coordinate a national approach to regulating electronic conveyancing. Its members are the land registrars, or their nominees, of the eight jurisdictions.

ARNECC's work is to keep the rules the same everywhere. It writes and maintains two model documents: the Model Operating Requirements, addressed to network operators, and the Model Participation Rules, addressed to the law firms, conveyancers and lenders that subscribe to a network. The model versions have no force by themselves. Each registrar then makes them as the operating requirements and participation rules of his or her own jurisdiction, which is the step that gives them legal effect in Queensland.

Enforcement likewise stays with each registrar. If a Queensland subscriber fails to verify a client's identity properly, the question of what happens is one for the Queensland Registrar of Titles, applying the Queensland version of the rules. ARNECC's website lists a national enforcement framework, compliance examinations and interoperability between networks among its current areas of work, which shows where the council's attention is, but the legal powers remain state by state.

## The Residential Tenancies Authority

The Residential Tenancies Authority (RTA) is a Queensland statutory body that administers the Residential Tenancies and Rooming Accommodation Act 2008. It holds rental bonds, publishes the approved forms, offers free dispute resolution and investigates and prosecutes offences against the Act.

Reforms that took effect in stages across 2024 and 2025 pushed the RTA deep into the territory of rental technology. From 30 September 2024, the RTA says, a managing party must give a tenant at least two ways to pay rent, one of which must not cost the tenant more than ordinary bank charges; fees charged by an online rent payment platform do not count as ordinary bank charges. From 1 May 2025, rental applications must be made on a standard form, applicants must be offered at least two ways to submit it, and one of those ways must not be restrictive, which the RTA defines to include a requirement to apply through an online platform or a third party who is not a real estate agent.

The same reforms limit the documents that may be requested from an applicant and set deadlines for destroying personal information. They are the clearest Queensland example of a regulator writing rules with apps and platforms squarely in mind, and they are enforced by the RTA through the offence provisions of the tenancy Act.

## The QBCC and the building side

The Queensland Building and Construction Commission (QBCC) licenses builders and trade contractors, administers the Queensland Home Warranty Scheme and handles complaints about defective building work. It is the least "digital" of the bodies in this map, and it appears here for completeness.

Its relevance to property technology is indirect. Platforms that match home owners with tradespeople, or that sell house and land packages online, are dealing in work that can only lawfully be carried out by QBCC licensees above the value thresholds set in the legislation. The QBCC's online licence search is the public check, and the insurance that protects a home owner under the warranty scheme attaches to the licensed contractor and the contract, not to the platform that introduced them.

## AUSTRAC: money laundering controls arrive in real estate

AUSTRAC, the Australian Transaction Reports and Analysis Centre, is the Commonwealth's financial intelligence agency and its anti-money-laundering regulator. Until now its reach into property has been through banks and other lenders. That changes on 1 July 2026, when amendments to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 bring a second group of businesses, known as tranche 2, under the regime.

AUSTRAC's published guidance says the new group includes real estate professionals who broker the sale, purchase or transfer of real estate, property developers who sell directly, and lawyers and conveyancers who act on property transactions. Each becomes a "reporting entity" when it provides a designated service. The duties that follow are substantial: enrolling with AUSTRAC, adopting an anti-money-laundering program built on a risk assessment, carrying out customer due diligence on clients, reporting suspicious matters, and keeping records.

For technology, two consequences stand out. Identity checking becomes a legal duty for agencies, where before it was a matter of practice, and many will meet it with electronic verification tools, which then have to meet AUSTRAC's standards for reliable and independent data. And the regime already covers businesses that exchange or transfer virtual assets: AUSTRAC regulates those providers as reporting entities in their own right, with the scope of regulated virtual asset services widened under the same amending Act.

## The OAIC and personal information

The Office of the Australian Information Commissioner (OAIC) administers the Privacy Act 1988 and its thirteen Australian Privacy Principles, which govern how personal information is collected, used, disclosed, secured and destroyed. It also runs the notifiable data breaches scheme.

Property technology is, to a large degree, a business of personal information: identity documents, income evidence, rental histories, inspection attendance, browsing behaviour on listing sites. Whether the Privacy Act applies depends first on size. According to the OAIC, a business with an annual turnover of $3 million or less is generally exempt, but the exemption falls away for several categories that are common in property. The OAIC's list includes businesses that trade in personal information, operators of residential tenancy databases, credit reporting bodies and reporting entities under the anti-money-laundering law.

That last category links two regulators. A small agency that becomes an AUSTRAC reporting entity on 1 July 2026 is brought under the Privacy Act for the information it handles to meet its anti-money-laundering duties, whatever its turnover. Larger agencies, franchise groups, portals and most software vendors are covered already.

Queensland has a separate privacy regime for its own public sector, overseen by the state's Office of the Information Commissioner. It governs how bodies such as the RTA handle the information they hold. It does not regulate private agencies or platforms.

## ASIC: investment products, fractional ownership and credit

The Australian Securities and Investments Commission (ASIC) regulates companies, financial products and financial services under the Corporations Act 2001, and consumer lending under the national credit legislation. Property enters its field whenever a home is turned into something to invest in or borrow against.

A platform that lets many people each buy a share in the returns of a property is, in most structures, operating a managed investment scheme. Offering interests in such a scheme to retail investors generally requires an Australian financial services licence, a registered scheme and a product disclosure statement. The same analysis applies when the interests are issued as digital tokens: ASIC's stated approach to digital assets is that the legal character of the product decides the rules, not the technology that records it.

On the lending side, anyone who provides or arranges consumer credit secured over residential property needs an Australian credit licence or must act under one, and is bound by the responsible lending obligations. Online mortgage brokers, digital lenders and comparison sites that go beyond pure information are all within that perimeter. ASIC also polices misleading conduct in relation to financial products, a role that overlaps with the consumer regulator's.

## The ACCC: claims, contract terms, competition and scams

The Australian Competition and Consumer Commission (ACCC) enforces the Competition and Consumer Act 2010, which contains the Australian Consumer Law. The consumer law's prohibition on misleading or deceptive conduct applies to any business in trade or commerce, so it covers a portal's claims about audience size, a platform's statements about fees, and the fine print of a subscription. Its unfair contract terms rules apply to standard form contracts with consumers and small businesses, which describes most software agreements an agency or a tenant will ever be offered.

The competition side matters because property technology markets are concentrated: a small number of portals, a small number of settlement networks. Mergers, exclusive dealing and misuse of market power are assessed by the ACCC under the same Act that governs every other industry.

The ACCC also has a growing role in scams. It runs the National Anti-Scam Centre, and the Scams Prevention Framework legislated by the Commonwealth in 2025 names it as the general regulator of the designated sectors.

> A product is rarely unregulated because no rule names it. It is usually caught by an older rule written for the activity it automates.

## Where the regulators overlap, and where gaps remain

Most real disputes about property technology involve more than one of these bodies, and the same facts can be looked at through several statutes.

<figure class="fig"><figcaption><b>One product, several regulators: three common cases</b></figcaption>
<div class="scroll"><table class="tbl">
<thead><tr><th>Product</th><th>Queensland rules</th><th>Commonwealth rules</th></tr></thead>
<tbody>
<tr><td>A rental application platform</td><td>RTA: standard form, submission methods, document limits, destruction deadlines</td><td>OAIC: privacy principles if the operator is covered; ACCC: fees and contract terms</td></tr>
<tr><td>An identity verification tool used by an agency</td><td>Registrar of Titles: identity standard where the user is a settlement network subscriber</td><td>AUSTRAC: customer due diligence from 1 July 2026; OAIC: handling of the identity data</td></tr>
<tr><td>A fractional property investment platform</td><td>OFT: licence if it acts as agent in a sale or letting; Registrar: who appears on title</td><td>ASIC: scheme registration, licence and disclosure; AUSTRAC if value is moved</td></tr>
</tbody>
</table></div></figure>

Two features of the map deserve a plain statement. First, several of these regimes regulate the professional and not the tool. The OFT holds the licensee responsible for trust money, the Registrar holds the subscriber responsible for verifying identity, and AUSTRAC holds the reporting entity responsible for its program. A vendor whose software fails may face a contract claim or a consumer law claim, but the regulatory consequence usually lands on the customer who relied on it.

Second, a complaint goes to the regulator of the conduct, not of the company. A tenant charged a fee to pay rent takes that to the RTA. A person whose identity documents were exposed by a covered organisation takes it to the OAIC. Someone misled by an advertisement for a property can raise it with the OFT; someone misled about an investment product, with ASIC. Disputes about money owed between the parties go to the Queensland Civil and Administrative Tribunal or the courts, which decide cases but do not regulate anyone.

<div class="callout"><span class="mono">Worth knowing</span><h4>Queensland has no licensed conveyancers</h4>
<p>In Queensland, conveyancing for reward is legal work carried out by solicitors and law practices, regulated under the Legal Profession Act 2007. Several other states license conveyancers separately. A rule or a product designed around licensed conveyancers elsewhere does not carry over automatically.</p>
</div>

What is described here is a snapshot. The anti-money-laundering extension begins on 1 July 2026, and ARNECC continues to revise its model rules. The structure, though, is stable: state law for people, land and tenancies, Commonwealth law for data, money and markets, and a national council holding the settlement rules together.
