Six weeks after the first tranche: where AMLA's standards stand
A status check in early September 2026: seven final reports, seven consultations closed and being finalised, three open, a dozen guidelines not yet drafted. What is settled, what is not, and what obliged entities should do this quarter.
21 September 2026. Correction: the guidelines this article listed as "final draft" have not been drafted yet, and the open consultations in early September were the STR template, the non-financial risk-assessment RTS and the FIU exchange RTS. Statuses and dates in this article were aligned with AMLA's publications (regulatory instruments overview of 4 September 2026, Single Programming Document 2026-2028). AMLA has published no final guideline yet; where an EBA guideline exists on a topic it continues to apply until AMLA replaces it.
Ten months before the AMLR applies, the regulatory picture is clearer than it was in spring, but not finished. This is where the instruments tracked on the AMLR Monitor dashboard stand at the start of September 2026, and what it means for the coming quarter.
Settled: the Level-1 texts
The AMLR, AMLD6 and the AMLA Regulation are published and in force; only their application dates lie ahead. Nothing in the Level-2 process can change the obligations they contain: the 25% beneficial ownership threshold, the compliance manager, the cash limit, suspicion-based reporting, the five-year retention period.
With the Commission, or being finalised
Of the RTS the EBA consulted in 2025, the risk-assessment methodology for financial supervisors and the selection RTS reached the Commission in December 2025, and the sanctions RTS was approved for transmission on 1 July 2026 (final report 8 July). The RTS on customer due diligence and on thresholds, re-consulted by AMLA until 8 May, are scheduled for their final drafts in the third quarter, as are the RTS on group-wide requirements and on home-host cooperation. Adoption as delegated regulations, scrutiny by Parliament and Council and publication in the Official Journal follow. Their substance is known; their exact legal wording is not yet final.
In consultation: three instruments
Three consultations are open in early September: the ITS on the suspicious transaction report template (until 20 September), the RTS on the risk profile of non-financial obliged entities (until 27 September) and the RTS on cross-border information exchange between FIUs (until 6 October). The Guidelines on the business-wide risk assessment (closed 15 July) and on ongoing monitoring (closed 3 September) are being finalised for the fourth quarter.
Not yet drafted: a dozen Guidelines with 2026 and 2027 deadlines
Internal policies and controls (consultation planned for the first quarter of 2027), risk factors (planned for the third quarter of 2026), outsourcing, reliance, PEPs, third-country risks, enhanced due diligence for crypto and for high-net-worth customers, indicators of suspicion, sanction base amounts, targeted financial sanctions and the joint guidelines with the EDPB on information-sharing partnerships. Where an EBA guideline exists on the topic it continues to apply until AMLA replaces it; design against the AMLR text and the EBA guidelines, and reserve capacity to adjust.
What this quarter should deliver
- A gap analysis on the compliance framework with owners per block.
- Consultation responses on the STR template and, for the non-financial sector, on the risk-assessment RTS where they touch your sector.
- The customer data model designed against the CDD RTS and the STR template together.
- The governance decisions: compliance manager, programme owner, board cadence.
What to watch
Commission adoption decisions on the first tranche, the closing dates of the open consultations, and the Dutch implementation act. The dashboard updates when a status changes, and the daily source check lists new publications the day they appear.