AMLA's simplified due diligence roundtables: what the new guidelines may bring

Between 9 November and 2 December 2026, AMLA will sit down in Frankfurt with representatives of the financial and the non-financial sector to talk about one of the most contested parts of the single rulebook: when an obliged entity may do less. The sectoral roundtables on simplified customer due diligence, announced in a press release of 2 October 2026, are the first step towards a set of own-initiative guidelines that AMLA has not yet drafted. The window to express interest closed on 18 October 2026, so the participant list is being settled now. Even firms that are not in the room should pay attention, because the outcome will shape how supervisors read Article 33 AMLR after 10 July 2027.

What AMLA announced

The press release is short, and so are the facts:

• AMLA invited obliged entity representatives, trade associations and other representative bodies from both the financial and the non-financial sector to express interest in sectoral roundtables on the application of simplified customer due diligence.
• The meetings are held in person in Frankfurt am Main between 9 November and 2 December 2026, organised by sector.
• The deadline for expressions of interest was 18 October 2026, 23:59 CEST.
• The feedback is meant to inform draft guidelines that, in AMLA's words, should support a clear, effective and proportionate application of simplified due diligence in situations of lower ML/TF risk.
• The guidelines are own-initiative guidelines, which AMLA may issue under Article 54 AMLAR without a specific mandate in the AMLR.

Several national supervisors relayed the invitation; the Luxembourg CSSF, for instance, explicitly encouraged professionals and their representative bodies to take part. No consultation date has been announced. Because the roundtables run into December, a consultation paper before 2027 looks unlikely, and AMLA's programming already schedules fourteen mandated instruments for 2027. The honest status is: announced, no draft yet.

Why simplified due diligence needs guidelines at all

The AMLR itself is more prescriptive on simplified measures than AMLD4 ever was, and that is precisely why practice needs guidance.

Article 33 AMLR lists what an obliged entity may do where, taking into account the risk factors of Annexes II and III, a business relationship or transaction presents a low degree of risk: postpone the verification of the identity of the customer and the beneficial owner, but no later than 60 days after the relationship is established; reduce the frequency of customer identification updates; reduce the information collected on the purpose and intended nature of the relationship, or infer it from the type of transactions; reduce the frequency or degree of transaction scrutiny; and apply other simplified measures identified by AMLA in the RTS under Article 28. The same article requires the simplified measures to be laid down in the firm's internal procedures, keeps the duty to monitor sufficiently to detect unusual or suspicious transactions, and withdraws the option where there are doubts about the information provided, where the low-risk factors are no longer present, or where monitoring shows that the risk is not low.

The RTS on customer due diligence under Article 28 AMLR, which AMLA submitted to the Commission on 1 October 2026 (status: Final text, awaiting publication), fills in the information to collect and verify under simplified, standard and enhanced due diligence. In the consultation many respondents asked for broader room for simplification. The final draft did not go far in that direction. Reading the roundtable announcement next to the CDD final report, the pattern is clear: AMLA treats the RTS as the legal floor and wants to handle the practical question, which situations in which sectors genuinely are low risk and what 'reduced' looks like, through guidelines rather than through binding technical standards.

That matters because of the different legal weight. An RTS, once adopted by the Commission, is directly applicable law. Guidelines under Article 54 AMLAR work on a comply-or-explain basis for supervisors, and obliged entities must make every effort to comply. Supervisors across the EU will therefore read the simplified due diligence guidelines as the benchmark for what they accept, and firms that deviate will need a documented reason.

The questions the roundtables are likely to raise

AMLA has not published an agenda. Based on the text of Article 33 AMLR, Annex II and the issues raised during the CDD consultation, the discussions will probably circle around the following points, and these are also the points on which your own position should be ready:

• Which customer types and products in your sector are in practice treated as low risk today, and on which evidence? Annex II lists factors such as listed companies subject to disclosure requirements, public administrations and enterprises, and certain low-value, restricted-use products. The question is how far sector practice goes beyond those examples.
• What does 'postponed verification within 60 days' look like operationally, and what limits apply to the account or service before verification is complete?
• What does a 'reduced frequency' of identification updates mean in years, and how does it interact with the event-driven reviews in the draft Guidelines on ongoing monitoring (status: Consultation closed, being finalised)?
• How can purpose and nature be inferred from the product rather than asked, and in which products is that defensible?
• How much transaction scrutiny can be reduced while still meeting the duty under Article 33 to detect unusual or suspicious transactions, and how does a firm evidence that trade-off?
• For the non-financial sector: which low-risk situations exist for notaries, accountants, tax advisers, estate agents and dealers in goods, where the customer base and the transaction pattern differ fundamentally from retail banking?
• Which national simplified regimes currently in force, for example for pooled accounts or certain life insurance products, should survive in an EU-wide form and which should not?

There is a second-order question that AMLA will have to answer itself: how the guidelines relate to the successor to the EBA Risk Factors Guidelines (status: EBA guideline in force, AMLA successor pending). Those guidelines already contain sectoral low-risk indicators and simplified measures. AMLA intends one common set of Risk Factor Guidelines covering seven mandates; a separate own-initiative text on simplified due diligence will need to sit cleanly on top of it.

What this means for programmes aiming at 10 July 2027

The practical risk is that firms treat simplified due diligence as a topic that can wait for the guidelines. It cannot. From 10 July 2027, Article 33 AMLR applies directly, with or without guidelines, and the RTS on CDD is expected to apply on the same date. Supervisors will then ask three things: which low-risk categories you have defined, where the justification is documented, and how you detect that a relationship has stopped being low risk.

The guidelines, when they come, will add detail and will probably narrow some national practices. Programmes should therefore build simplified due diligence in a way that can be tightened without a redesign:

• Anchor every simplified category in the business-wide risk assessment (draft Guidelines, status: Consultation closed, being finalised) and in the customer risk assessment under Article 20 AMLR, with explicit reference to the Annex II factors relied on.
• Describe the exact reduced measures per category in the internal procedures, as Article 33 requires, rather than a generic statement that 'reduced measures may apply'.
• Keep the fallback triggers machine-readable where possible: doubts about customer information, loss of a low-risk factor, or monitoring alerts should automatically escalate the customer to standard due diligence.
• Where you rely on postponed verification, set a hard 60-day control with service restrictions until verification is completed.

What to do now

• If your association is taking part in the roundtables, feed it concrete cases: product, customer type, volumes, current simplified measures and the evidence that they have not produced suspicious activity. Abstract pleas for proportionality carry little weight.
• Inventory the simplified due diligence you apply today under national law and map each case to Article 33 AMLR and Annex II. Flag the cases that rest on a national rule with no equivalent in the AMLR.
• Draft the Article 33 section of your CDD procedure now, on the basis of the final draft RTS on CDD, and mark it as subject to revision once the guidelines are consulted.
• Make sure the monitoring design for low-risk segments is documented: which scenarios still run, at which thresholds, and why that satisfies the duty to detect unusual transactions.
• Watch the AMLA consultation page in the first half of 2027 for the draft guidelines, and plan to respond; the roundtables are an input, not the consultation.

Also this week: AMLA holds the public hearing on the draft RTS for the central AML/CFT database on 3 November 2026, which we covered earlier. The AMLR Monitor dashboard tracks the RTS on CDD, the Guidelines on the business-wide risk assessment, the Guidelines on ongoing monitoring and the pending successor to the Risk Factors Guidelines, and will add the simplified due diligence guidelines as soon as AMLA publishes a draft.