What AMLA means for notaries, lawyers, accountants and estate agents
AMLA will not supervise notaries, lawyers, accountants or estate agents and charges them no fee. It still shapes their work, through the rules it writes and the peer reviews of their supervisors.
Most of what is written about AMLA, the EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism in Frankfurt, is about banks: the selection of up to 40 cross-border institutions for direct supervision, joint supervisory teams, an annual fee. For notaries, lawyers, accountants, tax advisers, estate agents, trust and company service providers, dealers in goods and gambling operators none of that applies. AMLA will not supervise them and will not charge them. It still changes their work, in two ways: through the rules it writes, and through the way it holds their supervisors to account.
AMLA will not be your supervisor
The AMLA Regulation, Regulation (EU) 2024/1620, limits direct supervision to credit and financial institutions that operate in at least six Member States (Article 12(1)). No notary office, law firm, accountancy practice or estate agency can be selected. Your supervisor stays national. In the Netherlands, for example, that is the BFT for notaries, accountants and tax advisers, the dean of the local bar for lawyers, the Bureau Toezicht Wwft for estate agents and dealers, DNB for trust offices and the Kansspelautoriteit for gambling operators. The annual supervisory fee in Article 77 is levied only on selected institutions and on other credit and financial institutions that meet the six-country test, so it does not reach the non-financial sector either.
AMLA holds your supervisor to account
Article 5(4) of the AMLA Regulation gives AMLA a set of tasks towards the supervisors of the non-financial sector:
- It coordinates peer reviews of their supervisory standards and practices (Article 35).
- It reviews periodically whether they have adequate resources and powers.
- It can investigate a supervisor that does not apply Union law, or applies it in a way that appears to breach it, issue recommendations and, when those are not followed, a warning that names the measures to take (Article 37).
- It facilitates supervisory colleges for cross-border groups in the non-financial sector, a new instrument, and can help supervisors that disagree about the measures to take (Articles 36 and 38).
Where a Member State leaves supervision to a self-regulatory body, such as a bar or a chamber of notaries, AMLA exercises these tasks towards the public authority that oversees that body. For a practice this means that the intensity and the method of supervision will converge across Member States. A supervisor that inspected rarely, or accepted thin risk assessments, will be compared with its peers.
AMLA writes the rules you apply
From 10 July 2027 the AMLR applies directly to every obliged entity, and much of its technical detail comes from AMLA: technical standards that the Commission adopts, and guidelines that supervisors and obliged entities follow on a comply-or-explain basis. Today's EBA guidelines are addressed to the financial sector, so for most non-financial sectors AMLA's guidelines will be the first EU-level guidance they have to follow. The texts that matter most for a non-financial practice, as they stand on 24 September 2026:
- RTS on customer due diligence. Which identity data you collect and verify, from which sources, and when simplified or enhanced measures apply. AMLA re-consulted its draft from 9 February to 8 May 2026; the consultation is closed and the final draft is scheduled for the third quarter of 2026.
- RTS on the risk profile of obliged entities in the non-financial sector (Article 40(2) AMLD6). The common method your supervisor will use to classify the risk profile of your practice, with data points per activity and a reduced set for small entities. In consultation until 27 September 2026; AMLA intends the method to apply from 31 December 2028.
- RTS on pecuniary sanctions and administrative measures. How breaches are graded and how fines are set, for the financial and the non-financial sector alike. AMLA re-consulted the EBA draft in February and March 2026 to hear the non-financial sector, and its General Board approved the final text on 1 July 2026; adoption by the Commission is still to follow.
- Guidelines on the business-wide risk assessment. Minimum content, method, review frequency and documentation. The consultation closed on 15 July 2026; the final draft is scheduled for the fourth quarter of 2026.
- ITS on reporting suspicions to the FIU. One EU format, with templates per type of obliged entity. The consultation closed on 20 September 2026; the final draft is scheduled for the fourth quarter of 2026.
- Guidelines on internal policies, procedures and controls. Among other things the staff of the compliance function and the situations in which the roles of compliance manager and compliance officer may be simplified, which matters to small practices. AMLA plans the consultation for the first quarter of 2027.
AMLA's explainer for the non-financial sector of 9 February 2026, with its consultation calendar, is the best single overview of what is coming.
What to do now
- Look at the non-financial risk-profile consultation before 27 September 2026. Check which data points apply to your activity and whether you can produce them; if they are unworkable, respond through the survey for your sector or through your professional body.
- Put the business-wide risk assessment in the AMLR structure. It is the document your supervisor will ask for first (Article 10 AMLR), and AMLA's guidelines on it are close to final.
- Decide who carries the compliance roles. The AMLR asks for a compliance manager at management-body level and a compliance officer (Article 11 AMLR). The AMLA guidelines on internal controls will say when a small practice may simplify them; until then, document who does what.
- Map client acceptance to the CDD RTS. Your identification forms and verification sources must follow it from 10 July 2027; start from the final draft as soon as AMLA publishes it.
- Ask your supervisor or professional body how it prepares. Its method will change when AMLA's standards and peer reviews apply, and so will what it asks of you.
The AMLR Monitor dashboard filters every AMLA text by type of obliged entity, including notaries, lawyers, accountants and estate agents, with its status and consultation deadline. The page What is AMLA? sets out the authority's five roles.