AMLA's annual supervisory fee: which institutions pay, selected or not
AMLA will charge an annual fee to the institutions it selects and to every credit or financial institution active in six or more Member States. Who pays, how it is calculated and what is still open.
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The selection of up to 40 institutions for direct AMLA supervision gets the attention, but a second consequence of the AMLA Regulation reaches further: the annual supervisory fee. Article 77 of Regulation (EU) 2024/1620 has AMLA levy it on every selected institution and on every other credit or financial institution that meets the criteria for the selection assessment, whether or not it is selected. A payment institution that passports its services into six Member States may never have AMLA as its supervisor, and still pay AMLA every year.
Who pays
- Selected obliged entities. The institutions and groups AMLA selects in 2027 and supervises directly during 2028 and after (Article 13).
- Non-selected institutions that meet the six-country test. Credit and financial institutions, and groups of them, that operate in at least six Member States, including the home Member State, through establishments or under the freedom to provide services, whether through infrastructure in the country or remotely (Article 12(1)).
No one else pays AMLA a supervisory fee. Institutions active in fewer than six Member States, and all non-financial obliged entities, fall outside Article 77.
What the fee pays for
The fees fund AMLA's supervisory work in the financial sector: the direct supervision of selected institutions and the oversight of the national financial supervisors (Articles 76(3) and 77(1)). They may not exceed the cost of those tasks, and a difference in one year is corrected in the fees of the two following years. AMLA's other revenue comes from a contribution from the EU budget and the other sources listed in Article 76(3).
How it is calculated
The fee is calculated at the highest level of consolidation in the Union, under the applicable accounting standards (Article 77(3)). The basis for a calendar year is AMLA's expenditure on the direct and indirect supervision of the institutions that pay in that year, and AMLA may ask for advance payments based on a reasonable estimate (Article 77(4)). The individual amount follows a methodology that the Commission sets in a delegated act, which has to take into account (Article 77(6)):
- the total annual turnover or the corresponding income at the highest level of consolidation in the Union;
- whether the institution has been selected for direct supervision;
- its risk profile under the selection methodology;
- its importance to the stability of the financial system or to the economy of one or more Member States or of the Union;
- a cap for non-selected institutions: in proportion to their turnover or income, their fee may not exceed 20 percent of the fee of a selected institution with the same level of turnover or income.
The Commission has to adopt that delegated act by 1 January 2027. Until it is adopted, nobody can calculate an individual fee.
National fees continue
The AMLA fee comes on top of what you pay your national supervisor. Article 77(5) keeps the right of financial supervisors to levy fees under national law for the tasks that have not moved to AMLA, and for the cost of cooperating with and assisting AMLA. Before deciding the final fee level, AMLA consults the financial supervisors so that supervision remains cost-effective and reasonable for all institutions (Article 77(4)).
What to do now
- Run the six-country test at group level. Count the Member States where the group has establishments or provides services, including remotely. The RTS on selection sets the minimum activity that counts; institutions that meet the test have reported eligibility data through their national supervisor in 2026, on the reporting package of 12 May 2026.
- Reserve for the fee once you meet the test. Selected or not, the amount follows from the delegated act, and AMLA may ask for advance payments.
- Check your turnover at the highest level of consolidation in the Union. It is the base of the fee; know which entity reports it and on which accounting standard.
- Read the delegated act when the Commission adopts it. It fixes the methodology and the collection procedure.
- Keep the risk profile in view. The risk classification that decides selection also feeds the fee, so the quality of the data you report through your supervisor matters twice.
The AMLR Monitor dashboard tracks the selection RTS and AMLA's timeline. The page What is AMLA? explains who AMLA supervises and what it means for other organisations.