RTS on customer due diligence (CDD)

What it covers

Specifies which information must be collected and verified when identifying the customer and beneficial owner, which reliable sources may be used, and the requirements for simplified and enhanced due diligence. The EBA consulted a first draft in 2025; AMLA re-consulted its own draft from 9 February to 8 May 2026 (public hearing 24 March 2026). On 1 October 2026 AMLA published the final report and submitted the final draft to the European Commission (press release of 1 October 2026); adoption and publication in the Official Journal still to follow.

What it means in practice

Affects almost the entire Client Acceptance column: onboarding data model, verification sources (incl. eID/EUDI wallet), SDD/EDD triggers and periodic review frequencies. Until the RTS applies, the EBA Guidelines on remote customer onboarding remain the reference for remote verification.

Versions and what changed

1. Consultation paperMarch 6, 2025
   EBA consultation paper (EBA/CP/2025)

   First public draft, prepared by the EBA. Consultation closed 6 June 2025.

   Sources
2. Consultation paperFebruary 9, 2026
   AMLA consultation paper on the draft RTS under Art. 28(1) AMLR

   AMLA re-consulted its own draft to capture the non-financial sector, which barely responded to the EBA round. Public hearing 24 March 2026; consultation closed 8 May 2026.

   Sources
3. Final draftOctober 1, 2026
   AMLA final report on the draft RTS under Art. 28(1) AMLR

   Final report published with the press release of 1 October 2026, after the statutory deadline of 10 July 2026 that AMLA had moved to the third quarter in its programming document. Compare the final text with the February draft before building on it.

   Sources
4. Submitted to the CommissionOctober 1, 2026
   Submitted to the European Commission for adoption

   The press release of 1 October 2026 states that the final draft standards are submitted to the Commission; adoption and publication in the Official Journal still to follow.

   Sources
5. Published in the Official Journalnot yet available

Consultation themes

• Is the list of identity data for natural and legal persons proportionate and complete?
• Which sources should count as reliable and independent for verification, including eID and digital identity wallets?
• Are the proposed simplified and enhanced due diligence measures workable for your customer base?
• How should existing customers be transitioned to the new requirements?

Sources

• AMLA - final report on the draft RTS under Art. 28(1) AMLR (customer due diligence)
• AMLA - press release: AMLA finalises key standards for the private sector (1 Oct 2026)
• AMLA - consultation on the draft RTS on customer due diligence (9 Feb - 8 May 2026)
• AMLA - planning of RTS, ITS and Guidelines: Annex XI to the Single Programming Document 2026-2028 (4 Feb 2026)
• EBA - consultation on 4 RTS under the AML package (6 Mar - 6 Jun 2025)
• AMLA - Authority for Anti-Money Laundering

Framework blocks it lands on

This instrument on the dashboard, with the other instruments and the framework: Open on the dashboard

Other instruments

• RTS on business relationships, occasional and linked transactions and lower CDD thresholdsFinal text, awaiting publication
• Guidelines on targeted financial sanctions (internal policies, procedures and controls)EBA guideline in force, AMLA successor pending
• Guidelines on politically exposed persons (PEPs)EBA guideline in force, AMLA successor pending
• Guidelines on ML/TF risks, trends and methods involving third countriesAnnounced, no draft yet
• Guidelines on EDD for correspondent relationships with crypto-asset service providers and on self-hosted addressesEBA guideline in force, AMLA successor pending
• Guidelines on establishing the wealth of high-net-worth customersAnnounced, no draft yet

Every RTS, Guideline and ITS under the AMLR