RTS on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries

What it covers

Minimum content of group-wide AML/CFT policies, procedures and controls, information sharing within the group, and the additional measures a group must take where a third country does not allow the group standard to be applied. Consulted from 16 April to 15 June 2026 (public hearing 20 May 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). Until the RTS applies, Commission Delegated Regulation (EU) 2019/758 on measures in certain third countries stays in force.

What it means in practice

Groups with foreign subsidiaries or branches: re-document the group policy, intra-group information sharing and the escalation for third countries with legal impediments.

Versions and what changed

1. Consultation paperApril 16, 2026
   AMLA consultation paper on the draft RTS under Art. 16(4) and 17(3) AMLR

   First public draft. Public hearing 20 May 2026; consultation closed 15 June 2026.

   Sources
2. Final draftOctober 1, 2026
   AMLA final report on the draft RTS under Art. 16(4) and 17(3) AMLR

   Final report published with the press release of 1 October 2026, together with the RTS on customer due diligence and on business relationships and thresholds.

   Sources
3. 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
4. Published in the Official Journalnot yet available

Consultation themes

• Is the minimum content of group-wide policies proportionate for your group structure?
• Which third countries create legal impediments and are the additional measures realistic?

Sources

• AMLA - final report on the draft RTS under Art. 16(4) and 17(3) AMLR (group-wide requirements)
• AMLA - press release: AMLA finalises key standards for the private sector (1 Oct 2026)
• AMLA - consultation on the draft RTS on group-wide requirements (16 Apr - 15 Jun 2026)
• AMLA - planning of RTS, ITS and Guidelines: Annex XI to the Single Programming Document 2026-2028 (4 Feb 2026)
• EUR-Lex - Delegated Regulation (EU) 2019/758 on additional measures in third countries (in force until the RTS under Art. 17(3) AMLR applies)
• AMLA - Authority for Anti-Money Laundering
• AMLR - Regulation (EU) 2024/1624 (EUR-Lex)

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 the assessment of the inherent and residual risk profile of obliged entities (financial sector)Final text, awaiting publication
• RTS on the selection of obliged entities for direct AMLA supervisionFinal text, awaiting publication
• RTS on pecuniary sanctions, administrative measures and periodic penalty paymentsFinal text, awaiting publication
• RTS on the duties of home and host supervisors and the modalities of their cooperationFinal text, awaiting publication
• RTS on central contact points of e-money issuers, payment service providers and crypto-asset service providersEBA guideline in force, AMLA successor pending
• ITS on cooperation within the AML/CFT supervisory system for the purposes of direct supervisionFinal text, awaiting publication

Every RTS, Guideline and ITS under the AMLR