Finance & admin

Real estate trust accounting: what can and can't go offshore

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The short answer

The preparation work can; the authority over the money cannot. An offshore assistant can match the bank feed, code invoices, chase arrears, put owner statements together and build the month-end reconciliation for someone licensed to check and sign it. What they cannot do is move money out of the trust account, hold the bank login or approve a payment. Each state and territory sets its own rules, and whether receipting itself sits offshore is a call for the licensed person running your agency.

You can send nearly all of the preparation offshore and none of the authority. Trust money is held under your state or territory's agents legislation, and the authority to move it belongs to a licensed person in that jurisdiction. No amount of good process, close supervision or careful contract drafting transfers it.

That still leaves most of the hours on the table. Agency trust accounting is matching, coding, chasing, checking and assembling, with a short authorisation at the end. The authorisation is the regulated act. Everything leading up to it is administration, and administration travels.

The line is the bank, not the software

Two different things get called "the trust account", and keeping them apart is most of the answer.

The first is the trust bank account itself: the authorised deposit-taking institution, the signatories, the payment file, the withdrawal. That is where the licensing sits and it is closed. No offshore team member is a signatory, holds banking credentials, carries the token or the authenticator, or releases a payment. We treat this as the rule with no exceptions, and an auditor will test it.

The second is the trust ledger inside your property management platform, whether that is PropertyMe, Console Cloud, PropertyTree or REST Professional. That is a regulated record and it will be audited, but it is not the bank, and preparing a record for a licensee to review is not moving money out of an account. Nearly every confused conversation about offshore trust support is that distinction being skipped.

For a general agency assistant doing listings, CRM and campaigns, the answer is no trust access at all. What follows matters only if you are hiring a dedicated trust role.

What can be prepared offshore

The list is the same whether the person sits in Manila or your own back office.

  • Daily receipting and allocation. Direct debit and BPAY payments matched to the right tenancy, part payments split correctly across rent and water, unidentified deposits queued for a property manager to identify.
  • Bank feed work. Matched items cleared each morning, unpresented deposits and dishonours investigated, and the exception list produced before anyone signs anything.
  • The monthly reconciliation pack. Cash book to bank statement to the total of ledger balances, unpresented items scheduled, handed to your licensee to sign within the period your state prescribes.
  • Disbursement runs, prepared and not released. Cleared funds checked, agreed reserves held back, invoices scheduled, owner bank details verified against a written instruction.
  • Creditor invoices. Trade, water, council, insurance and smoke alarm invoices entered against the correct property and owner ledger, with work order approval and job completion checked first.
  • Owner statements. Produced to your template and checked for negative balances, missing rent and unallocated receipts before release.
  • Arrears. Chased on your escalation schedule with every contact logged, and breach paperwork prepared for your licensed staff to issue.
  • Bond tracking. Lodgements, transfers and refunds reconciled against the state bond authority's records.
  • The audit pack. Receipts, cash books, ledgers, statements, reconciliations and authorisation records assembled and indexed, with auditor queries answered.

None of that requires a licence, and all of it ends in something a licensed person reviews. Reviewing a completed reconciliation takes a fraction of the time building one does.

What cannot leave your licensed staff

  • Authorising or releasing any payment out of trust. Not the disbursement run, not a refund, not a transfer of your own fees.
  • Being a signatory, or holding anything that works like one. Bank portal logins, payment approval rights and second-factor devices all count.
  • Signing off the reconciliation. They build it; the licensed person reviews it and carries responsibility for it.
  • Releasing a sales deposit. Deciding a contract has gone unconditional is a licensed judgement, not a data check.
  • Dealing with the regulator and the audit report. Lodgement and attestation sit with the licence holder.
  • Anything your state's Act names as a function of the licensee in charge or principal agent. Read that section before you scope the role, not after.

The test that holds up across every profession: if the output requires someone to attest to it, the attesting act stays with the person whose licence it is.

Receipting is where reasonable people disagree

Entering a receipt does not move money. The money already arrived and the entry records where it landed, so on that reading receipting is preparation, which is how a dedicated real estate account assistant role is usually built.

The counter-argument is real too. A receipt writes to a regulated record an auditor will examine, and your state's rules govern how those records are made, amended and evidenced. Some licensees decide every write to the trust ledger stays onshore.

Both positions are defensible, and the call is your licensee in charge's rather than ours. If you land on the permissive side, scope it tightly: entry rights only, no authorisation rights, no ability to delete or backdate. If you land on the conservative side, the surrounding work still comes off the desk, and that is where most of the hours were anyway.

"Check your state" is the answer, not a dodge

There is no national real estate trust accounting law. Each state and territory runs its own, and the differences are not cosmetic. Who may authorise a withdrawal and what that person is called, how fast money must be banked, how often you reconcile, and who the audit goes to all vary.

In New South Wales, only the licensee in charge may authorise a trust account withdrawal, and that authority cannot be delegated (Property and Stock Agents Act 2002 (NSW)). In Queensland, section 9 of the Agents Financial Administration Act 2014 (Qld) allows only a principal agent to open a general or special trust account. In the ACT, section 107 of the Agents Act 2003 (ACT) requires trust money to be banked by the next ADI business day after it is received. In the Northern Territory, trust records must be audited within three months of the end of each prescribed period under the Agents Licensing Act 1979 (NT). Four jurisdictions, four different answers.

Where you operateThe instrument to readWho administers it
New South WalesProperty and Stock Agents Act 2002 and the Property and Stock Agents Regulation 2022NSW Fair Trading
VictoriaEstate Agents Act 1980Consumer Affairs Victoria
QueenslandAgents Financial Administration Act 2014 and Regulation 2014Office of Fair Trading Queensland
Western AustraliaReal Estate and Business Agents Act 1978 and the General Regulations 1979Consumer Protection WA
South AustraliaLand Agents Act 1994Consumer and Business Services
TasmaniaProperty Agents and Land Transactions Act 2016Property Agents Board of Tasmania
Australian Capital TerritoryAgents Act 2003Access Canberra
Northern TerritoryAgents Licensing Act 1979Agents Licensing Board (Licensing NT)

Acts get amended and section numbers move, so treat that table as where to start rather than as a citation. If you operate across borders, scope the role to the strictest rules you are subject to rather than running two standards.

How to set the access up so your auditor is comfortable

The controls are not exotic. They are the ones you would want around any remote finance person, and they get skipped because nobody writes them down.

Give a named user, never a shared login, so every entry is attributed to a person. Set role-based rights that exclude authorisation, deletion and backdating, and check what your platform actually enforces rather than what the sales page implies.

Keep banking entirely separate. Not the trust bank portal, not a saved session, not the authenticator, not a screenshot of a code. If a process only works because someone offshore can read a one-time code, it is broken.

Verify owner bank detail changes by voice, from your side, to a number you already held. Payment redirection fraud targets exactly this workflow and does not care where your staff sit. Keep that verification onshore and record it.

Then write the boundary down before day one and put it in the induction pack. Every failure we have seen came from an undocumented line rather than a defiant person: a capable team member with no written boundary makes a reasonable decision, and reasonable is not always compliant. Your obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles follow the data wherever the person sits, so scope access to the role and revoke it the day it is no longer needed.

Keep the review step permanently, even after twelve good months. It is not a comment on the person; it is what the legislation requires.

What to do next

Read your own state or territory's Act before you write the position description, and get your licensee in charge to name on one page which acts are theirs. That page is what makes the rest safe.

For the daily version, the arrears officer and property management assistant roles show what comes off the desk first. What a real estate agency should delegate first sets the handover order, what you legally cannot delegate offshore maps the same boundary across other regulated professions, and the real estate and property management pages cover the wider set of roles.

When you are ready to scope it against your own portfolio and state, book a discovery call and we will map which tasks fall on which side of the line before you commit.

This is general information, not legal, accounting or financial advice. Trust accounting obligations differ by state and territory and change over time. Check your own jurisdiction's Act and regulator, and confirm your arrangement with your licensee in charge and your trust account auditor.

How we would staff this

How we would staff this: everything up to the signature

You do not need another licensed person. You need the hours underneath the one you already have. We hire a full-time, dedicated trust accounting assistant in the Philippines on your behalf — working your business hours in your PropertyMe, Console Cloud, PropertyTree or REST Professional, under a named user you set up with authorisation, deletion and backdating rights switched off — from A$14 an hour plus GST, with no placement or setup fee and roughly two weeks from brief to first day.

Real estate account assistant, scoped to trust accounting support
What they do
  • Receipts the day's rent, matches direct debit and BPAY payments to the right tenancy, splits part payments correctly across rent and water, and queues unidentified deposits for a property manager to identify.
  • Works the trust bank feed every morning: clears matched items, investigates unpresented deposits and dishonours, and hands your licensee the exception list before anything gets signed.
  • Builds the month-end reconciliation — cash book to bank statement to the total of ledger balances, unpresented items scheduled — and produces owner statements checked for negative balances, missing rent and unallocated receipts, ready for your licensee in charge to review and sign inside the period your state prescribes.
  • Prepares the disbursement run without releasing it: cleared funds checked, agreed reserves held back, creditor invoices coded to the correct property and owner ledger, owner bank details checked against the written instruction already on file, with any change to those details verified by voice from your side.
  • Chases arrears on your escalation schedule with every contact logged, prepares breach paperwork for your licensed staff to issue, reconciles bonds against the state authority's records, and assembles and indexes the audit pack.
What stays with you
  • Authorising or releasing anything out of trust — the disbursement run, a refund, a transfer of your own fees. No offshore team member is a signatory, holds the trust bank login or payment approval rights, or has the authenticator.
  • Signing off the reconciliation, and deciding a contract has gone unconditional so the sales deposit can be released.
  • Dealing with the regulator, lodging the audit report, and anything your state's Act names as a function of the licensee in charge or principal agent.
  • The call on whether receipting itself sits offshore at all. That is your licensee in charge's decision, not ours, and we scope the role to whichever way it lands.
From A$14/hr + GST · full-time and dedicated · about two weeks from brief to first day · no placement or exit fees
See the role →

Frequently asked questions

Is it legal to have offshore staff working on an Australian real estate trust account?
Yes, as long as the licensed acts stay with your licensed people. State and territory agents legislation regulates who may open a trust account, who may authorise a withdrawal and who signs the reconciliation, and those are licensed roles. Preparing the records underneath — receipting, bank feed matching, owner statements, the month-end pack — is administration, and it can sit offshore. The rules differ between states and territories, so confirm the scope with your licensee in charge and your trust account auditor before day one.
Who is responsible if an offshore assistant makes a mistake in the trust account?
You are. Responsibility for trust money sits with the licence holder and whoever your state's Act names as running the agency — the licensee in charge, or the principal agent in Queensland. It does not move because the data entry happened somewhere else, any more than it would for a local junior. So the review step is permanent: the licensed person checks the reconciliation, the exception list and the disbursement run before authorising anything, and keeps checking after twelve good months.
Do I need to tell my trust account auditor that offshore staff prepare the reconciliation?
Yes, and tell them at the start of the engagement rather than during fieldwork. Auditors test who had access to the trust ledger, who authorised each withdrawal, and whether the reconciliation was signed inside the period your state prescribes, so named user logins, role-based permissions and clean authorisation records are what they will want to see. Hand over your written boundary document and the platform's user permission report up front. If your auditor wants tighter controls than you have built, that is far cheaper to hear early.
Does an offshore trust accounting assistant need a real estate licence or certificate of registration?
Not for preparation work, provided the role is scoped that way. Licensing attaches to the regulated acts — authorising withdrawals, releasing sales deposits, signing off the reconciliation, dealing with the regulator — and none of those go offshore. What matters instead is hands-on experience in your platform, whether that is PropertyMe, Console Cloud, PropertyTree or REST Professional, and in trust reconciliation itself. You check that in the interview, and your licensee in charge still reviews everything the role produces.
Can an offshore assistant contact tenants and owners directly?
Yes for administration, no for anything requiring a licence or a judgement call. Arrears reminders on your escalation schedule, receipt and payment queries, owner statement questions and chasing a missing invoice are all fine, with every contact logged in your system. Issuing a breach notice, negotiating rent, agreeing a payment arrangement or advising an owner on a decision are not — the assistant prepares the paperwork and your licensed staff issue it. Verify owner bank detail changes by voice from your side, onshore.
How much does an offshore real estate trust accounting assistant cost and how fast can they start?
From A$14 an hour plus GST for a full-time, dedicated team member if you are in Australia, or from US$9 an hour for US clients, with specialist roles higher. There are no placement, recruitment, setup or exit fees. Expect roughly two weeks from your brief to their first day, on an initial three month contract and then month to month. You interview and choose the person and direct the work; we hire them in the Philippines on your behalf and handle pay, HR and cover.
Sources & further reading
  • Property and Stock Agents Act 2002 (NSW) and Property and Stock Agents Regulation 2022 (NSW) — The New South Wales row of the state-by-state table of governing instruments
  • NSW Fair Trading, 'Real estate trust accounts and audit requirements' — Only a licensee in charge may authorise a NSW trust account withdrawal, and cannot delegate that authority
  • Agents Financial Administration Act 2014 (Qld) s 9 ('Who may open trust account'), and Agents Financial Administration Regulation 2014 (Qld) — In Queensland, only a principal agent may open a general or special trust account
  • Agents Act 2003 (ACT) s 107 ('Dealing with trust money'), subsection (2) — In the ACT, trust money must be banked by the next ADI business day after it is received
  • Agents Licensing Act 1979 (NT), with NT Government guidance 'Auditing your trust account' — In the Northern Territory, trust records must be audited within three months of the end of the prescribed period
  • Estate Agents Act 1980 (Vic); Real Estate and Business Agents Act 1978 (WA) and General Regulations 1979; Land Agents Act 1994 (SA); Property Agents and Land Transactions Act 2016 (Tas) — The remaining rows of the table showing which instrument and which regulator applies in each jurisdiction
  • Privacy Act 1988 (Cth) and the Australian Privacy Principles (Office of the Australian Information Commissioner) — Privacy obligations follow the data regardless of where the team member sits
Alfie Quiming
Alfie QuimingAccount manager, Manila

Alfie is a natural facilitator with a passion for building meaningful relationships. A true people person, he thrives on creating genuine connections and bringing people and businesses together, and he excels at fostering collaboration and teamwork. At StaffingSolutions.io he is usually the first person you speak to: he maps the role, writes the brief the recruiters work from, and stays on the account long after the placement.

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