Not necessarily. Registrations in most existing security interest registers will be migrated to the PPS Register.

If there is no existing register, security interest holders (grantees) will have 24 months (from May 2011) to consider whether existing security interests should be registered. Failure to register within the 24 months may result in a loss of priority to other security interests, or loss of the security interest on the sale of the collateral or the insolvency of the grantor. (Section 322).

Section 310 states that the Act will apply at the registration commencement time in relation to the following interests:
• a security agreement made at or after the registration commencement time;
• a security interest (other than a transitional security interest) arising at or after the registration commencement time;
• a transitional security agreement;
• a transitional security interest (whether arising before, at or after the registration commencement time);
an interest in personal property (other than a security interest) arising at or after the registration commencement time;
• personal property of a kind prescribed by the regulations;
• personal property, if data in relation to the property is given to the Registrar.

The registration commencement time will be the day the PPS Register commences operation. The registration commencement time will be the start of the first day of the month that is 26 months after the month in which the Act was given Royal Assent (15 December 2009), or an earlier time determined by the Minister , expected to be May 2011. If the Minister determines an earlier time to be the registration commencement time, that time must be at least 28 days after the migration time .

Although the Act commenced on the day after it received Royal Assent, the transitional provisions provide that a person will only be able to apply to register a financing statement or a financing change statement and the Registrar will only be able to register a financing statement, or a financing change statement, at or after the registration commencement time. The Registrar would also only able to register a financing statement or a financing change statement at his or her own initiative at or after the registration commencement time .

Part 9.4 of the Act sets out the rules to support the migration process and early registrations of transitional security interests. The migration time in the Act will be the start of the first day of the month that is 25 months after the month in which the Act is given Royal Assent or an earlier time determined by the Minister . If the Minister determines an earlier time to be the migration time, as is expected, the Minister would also determine an earlier time for the registration commencement time.