Regulatory monitor · status as of 21 Sept 2026

AMLR Framework: Integrated Compliance Architecture

The status of every RTS, Guideline and ITS under the EU AML package, mapped onto the compliance framework. Click a block for its instruments, summary, impact and source links.

34 RTS / GL / ITSChecked dailyEBA · AMLA · EUR-LexEN · NL · FR · DE · ESEncrypted
AMLR applies10 Jul 2027
292
days until 10 Jul 2027
2 in consultation7 consultation closed, being finalised2 published / definitive
Where the 34 Level-2/3 instruments stand
At a glance. 32 of the 34 Level-2/3 instruments are not yet definitive. The AMLR itself is final and applies in 292 days; the detailed rules are still to come. The greatest uncertainty sits in:
Status as of 21 Sept 2026. Sources: EBA, AMLA, EUR-Lex.

Next deadlines and expected dates

Latest updates

Status reviewed Sep 21, 2026Sources checked Sep 21, 2026

Latest steps of the RTS, Guidelines and ITS

  • 2026-07-21ITSITS Supervisory cooperation: AMLA final report on the draft ITS under Art. 15(3) AMLAR · Final report published with a press release on 21 July 2026: how AMLA and national financial supervisors cooperate in the selection process and the transfer of supervisory powers for directly supervised institutions. After the consultation AMLA added an exemption from the eligibility data collection where a supervisor can already establish that an entity is not eligible.Source
  • 2026-07-13RTSRTS Risk assessment (non-financial): AMLA consultation paper on the draft RTS under Art. 40(2) AMLD6 for the non-financial sector · First public draft, with Annexes I and II listing the data points per activity and a reduced set for small entities. Public hearing 10 September 2026; consultation closes 27 September 2026. AMLA intends the methodology to apply from 31 December 2028.Source
  • 2026-07-08RTSRTS Sanctions & measures: AMLA final report on the draft RTS under Art. 53(10) AMLD6 · Published with a press release on 8 July 2026. Compared with the consultation paper, Articles 1, 2 and 4 and the recitals were amended so the RTS applies to the financial and the non-financial sector alike: a shared list of gravity indicators, four levels of gravity and common criteria for the level of sanctions and measures.Source
  • 2026-07-06RTSRTS FIU cross-border exchange: AMLA consultation paper on the draft RTS under Art. 31(3) AMLD6 · First public draft. Consultation closes 6 October 2026. The criteria are built on structured data so that FIU.net can apply them automatically.Source
  • 2026-07-03ITSITS AMLA reporting to EPPO: AMLA final report on the draft ITS under Art. 41(2) AMLAR · Final report published with a press release on 3 July 2026: the same nine-section template as for FIUs, applied to AMLA's reports on joint analyses. Machine-readable reporting applies from 10 July 2028.Source
  • 2026-07-03ITSITS AMLA reporting to EPPO: Submitted to the European Commission for adoption · AMLA's press release of 3 July 2026 states that the three standards are submitted to the Commission for adoption and publication in the Official Journal.Source

1Framework

n In consultationn Consultation closed, being finalisedn Final text, awaiting publicationn EBA guideline in force, AMLA successor pendingn Announced, no draft yetn Published
Strategy & Risk
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Governance, policies & oversight
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People, culture & conduct
Client Lifecycle
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Data, technology & detection
14
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2All instruments

In consultation2
+1 Level-1 or national
Closed, being finalised7
Final, awaiting publication7
EBA applies, AMLA pending7
Announced, no draft9
Published2
+7 Level-1 or national

3Developments & milestones

Completed

  1. 15 Aug 2026
    Eligibility data for direct supervision due at AMLA
    National supervisors deliver the data on provisionally eligible credit and financial institutions (six or more Member States, reference date 31 December 2025); AMLA expects the provisional list by the end of September 2026.
    AMLA - reporting package for the identification of provisionally eligible obliged entities (12 May 2026)
  2. 1 Jan 2026
    EBA hands over its AML/CFT mandates to AMLA
    All AML/CFT mandates and functions, including the EuReCA database, transferred from the EBA to AMLA. Existing EBA guidelines and standards remain in force until AMLA replaces them (Art. 54(5) AMLAR).
    AMLA - EBA and AMLA complete the handover of AML/CFT mandates (19 Jan 2026)
  3. 1 Jul 2025
    AMLA operational in Frankfurt
    AMLA became operational on 1 July 2025 (Art. 108 AMLAR); the Commission remained responsible for its establishment until 31 December 2025.
    AMLA - Authority for Anti-Money Laundering
  4. 6 Mar 2025
    EBA consults on four RTS under the AML package
    On the Commission's request the EBA consulted the RTS on CDD, on the risk assessment of obliged entities, on AMLA selection and on sanctions (closed 6 June 2025) and delivered its advice on 31 October 2025. AMLA re-consulted three of them in 2026 to hear the non-financial sector.
    EBA - consultation on 4 RTS under the AML package (6 Mar - 6 Jun 2025)

Upcoming

  1. 1 Jan 2027 in 102 days
    Data collection for the 2027 selection (January to March)
    Provisionally eligible institutions report the selection data through their national supervisor, reference date 31 December 2026, in the EBA reporting framework 4.4.
    AMLA - EBA draft reporting framework 4.4 for the 2027 eligibility data collection (4 Aug 2026)
  2. 1 Jul 2027 in 283 days
    AMLA starts the first selection for direct supervision
    Selection of up to 40 cross-border credit and financial institutions from 1 July 2027 (Art. 13(4) AMLAR); the outcome is communicated by the end of 2027 and repeated every three years.
    AMLA - explainer: towards direct supervision, timeline of the 2027 selection (26 Jan 2026)
  3. 1 Jan 2028 in 467 days
    AMLA direct supervision starts during 2028
    Direct supervision begins six months after publication of the selection list (Art. 13(4) AMLAR); AMLA says "during 2028". Shown at 1 January as the earliest date.
    AMLA - explainer: towards direct supervision, timeline of the 2027 selection (26 Jan 2026)
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From the blog

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Beyond 10 July 2027

467 days until AMLA direct supervision (during 2028)

The application date is the start of supervision, not the end of the work. AMLA keeps issuing and revising Guidelines and technical standards, direct supervision starts in 2028, and the AMLR turns compliance into a standing set of recurring obligations.

  1. Now

    Prepare

    Gap analysis against the AMLR text, redesign of onboarding, monitoring and reporting, and responses to AMLA consultations while the RTS, ITS and Guidelines are still being finalised.

  2. 10 Jul 2027

    AMLR applies

    The AMLR obligations apply directly. National supervisors (in the Netherlands DNB, AFM and BFT) supervise under the AMLD6 implementation act. First supervisory reviews test the new customer due diligence, beneficial-ownership and reporting processes.

  3. 2028

    AMLA direct supervision

    AMLA directly supervises the first group of up to 40 cross-border financial institutions selected in 2027, through joint supervisory teams with the national supervisors. AMLA can also take over supervision of other entities in specific cases and coordinates the supervisory colleges.

  4. 10 Jul 2029

    Football sector

    Professional football clubs and agents become obliged entities. Institutions serving them adjust their risk assessment and due diligence.

  5. Ongoing

    Maintain

    AMLA keeps issuing and revising Guidelines, Q&As and technical standards; the Commission updates the high-risk third-country list and runs the supranational risk assessment. Compliance shifts from a project to a standing register of obligations, reviews and findings.

Recurring obligations after go-live

ObligationWhat it involvesCadenceFramework blocks
Business-wide risk assessment (SIRA)Reassess ML/TF risks per product, customer, country and channel; document and approve.At least yearly, and after material change
Business Wide Risk Assessment / SIRARisk AppetitePolicies & procedures
Periodic customer reviewsRefresh customer data, beneficial owners and risk classification; event-driven reviews on triggers.Per risk class (high risk yearly)
Periodic reviewClient Risk Assessment resulting in new/updated/confirmed AML/CFT risk classification
Compliance reporting to the management bodyThe compliance officer reports on the state of compliance, findings and resources.At least yearly
Compliance functionGovernanceManagement information & reporting
Suspicious transaction reportingReport to the FIU on the common template; keep the analysis behind each report.Continuous
FIU ReportingAlert handling
Training and awarenessTrain staff and the management body; keep records.Yearly and at onboarding
Employee Training & Awareness
Regulatory watchFollow new and revised AMLA Guidelines, RTS/ITS, the high-risk country list and national guidance.Continuous (this site checks sources daily)
Policies & proceduresRisk Management and Controls
Supervisory data and AMLA selectionDeliver the data that feeds the supervisory risk profile; prepare for possible selection for direct supervision.Selection rounds every three years
Management information & reportingData & analytics
Record retention and data protectionKeep records five years, then delete; balance with the GDPR.Continuous
Record RetentionData & analytics

Frequently asked questions

What is the AMLR?

The AMLR is Regulation (EU) 2024/1624, the EU Anti-Money Laundering Regulation. It is the "single rulebook" of the EU AML package: directly applicable customer due diligence, beneficial ownership, internal control and reporting obligations for obliged entities across the EU. It applies from 10 July 2027.

When does the AMLR apply?

The AMLR applies from 10 July 2027 (Article 90). Football clubs and agents follow from 10 July 2029. The same date, 10 July 2027, is the transposition deadline of the Sixth Anti-Money Laundering Directive (AMLD6, Directive (EU) 2024/1640).

What is the difference between an RTS, an ITS and a Guideline?

A Regulatory Technical Standard (RTS) is a binding delegated act that specifies how an AMLR article must be applied; AMLA drafts it and the European Commission adopts it. An Implementing Technical Standard (ITS) is a binding act that sets formats and templates, such as the template for reporting suspicious transactions. Guidelines are issued by AMLA on a comply-or-explain basis and set supervisory expectations without being directly binding law.

Who is AMLA?

AMLA is the Authority for Anti-Money Laundering and Countering the Financing of Terrorism, established by Regulation (EU) 2024/1620 and based in Frankfurt. It became operational in 2025, develops the RTS, ITS and Guidelines under the AML package, and will directly supervise a first group of up to 40 cross-border financial institutions from 2028.

What does "RTS in consultation" mean?

A draft RTS has been published for public consultation. Obliged entities and industry bodies can respond until the consultation closes. After that the draft is finalised, submitted to the European Commission and adopted as a delegated regulation, then published in the Official Journal of the EU.

What changes for Dutch institutions compared with the Wwft?

Most Wwft obligations are replaced by the directly applicable AMLR; the Dutch implementation act keeps national elements such as supervision by DNB, AFM and BFT, FIU-Netherlands reporting and possibly lower cash limits. Key changes include suspicion-based reporting instead of "unusual transaction" indicators, an EU-wide beneficial ownership threshold, a board-level compliance manager and harmonised enhanced due diligence.

What happens after 10 July 2027?

From 10 July 2027 the AMLR obligations apply and national supervisors review compliance under the AMLD6 implementation act. From 2028 AMLA directly supervises a first group of up to 40 cross-border financial institutions selected in 2027, with new selection rounds every three years. From 10 July 2029 football clubs and agents are covered. AMLA keeps issuing and revising Guidelines, Q&As and technical standards, so compliance becomes a standing cycle of risk assessments, periodic customer reviews, reporting and training rather than a one-off project.

What can I do with AMLR Monitor?

The public dashboard shows the status of every RTS, Guideline and ITS under the AMLR, filtered by type of obliged entity, mapped onto a compliance framework with article links and "what changes" notes. The workspace (free account per organisation) adds a company profile with an AI impact assessment, a readiness tracker shown as a heat map, country-specific points for every EU country, an AI consultant that knows your organisation, consultation tracking, daily source alerts, tasks, a team, exports and a board report.

How often is this dashboard updated?

Regulatory statuses are reviewed manually and dated on the page. In addition, an automated check fetches the EBA, AMLA, EUR-Lex and DNB source pages every day and lists any new AML-related publication for signed-in users in the workspace.

Who must comply with the AMLR?

Every obliged entity in Article 3 AMLR: credit and financial institutions, payment and e-money institutions, investment firms and fund managers, life insurers, crypto-asset service providers, crowdfunding platforms, trust and company service providers, accountants, tax advisers, lawyers and notaries for listed transactions, estate agents, dealers in high-value goods, gambling operators and, from 2029, professional football clubs and agents. The overview page lists every type with its scope.

What is the AMLR cash limit?

Traders in goods and services may not accept cash payments of 10,000 euro or more (Article 80 AMLR). Member States may set a lower limit; the Netherlands has 3,000 euro. Payments between private individuals and payments at credit, payment and e-money institutions are excluded.

What is the beneficial ownership threshold under the AMLR?

25 percent of shares, voting rights or other ownership interest, directly or indirectly, plus control through other means such as veto rights or the power to appoint the majority of the board (Articles 51 to 56). Member States may set a lower threshold for high-risk sectors.

Does the AMLR apply to crypto-asset service providers?

Yes. MiCA-licensed CASPs are obliged entities under the AMLR with specific enhanced due diligence for cross-border correspondent relationships and self-hosted addresses (Articles 37 and 38), next to the Transfer of Funds Regulation travel rule.

What do the statuses on the dashboard mean?

In consultation: a draft is open for comment. Consultation closed, being finalised: AMLA processes the responses. Final text, awaiting publication: adopted or submitted to the Commission, not yet in the Official Journal. EBA guideline in force, AMLA successor pending: the current EBA guideline applies today; AMLA's replacement under the AMLR is not yet consulted on or published. Published: in force or applying from the date shown.

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