RTS on the assessment of the inherent and residual risk profile of obliged entities in the non-financial sector
- Articles
- Art. 40(2) AMLD6
- Legal basis
- AMLD6 art. 40(2)
- Consultation closed
- September 27, 2026
- Expected
- December 31, 2026
- Applies to
- Trust or company service provider, Accountant / auditor, Tax adviser, Lawyer / notary, External compliance / CDD adviser, Estate agent / valuer, Dealer in high-value goods, Auction house, Gambling operator, Football club / agent, Other obliged entity
A draft is open for public comment. Obliged entities and industry bodies can respond until the deadline; the text will still change.
What it covers
Common methodology for the supervisors of the non-financial sector (lawyers, notaries, accountants, tax advisers, trust and company service providers, real-estate agents, dealers in goods, gambling operators, football clubs and agents) to assess and classify the ML/TF risk profile of the entities they supervise: data points per activity, a reduced set for small entities, and the resulting risk categories. Consulted by AMLA from 13 July to 27 September 2026 (public hearing 10 September 2026); final draft scheduled for Q4 2026; AMLA intends the methodology to apply from 31 December 2028.
What it means in practice
Determines how your supervisor rates your practice or business and how much attention it gets. Expect a periodic data request on customers, services, geography and controls in the format of the RTS; check which data points apply to your activity and whether your systems can produce them. Respond to the consultation (one survey per sector) if the data points or the treatment of small entities are unworkable.
Versions and what changed
- Consultation paperJuly 13, 2026AMLA consultation paper on the draft RTS under Art. 40(2) AMLD6 for the non-financial sector
First public draft, with Annexes I and II listing the data points per activity and a reduced set for small entities. Public hearing 10 September 2026; consultation closes 27 September 2026. AMLA intends the methodology to apply from 31 December 2028.
Sources - Final draftnot yet available
- Submitted to the Commissionnot yet available
- Published in the Official Journalnot yet available
Consultation themes
- Are the data points for your activity relevant and proportionate, and can your systems produce them?
- Is the reduced set of data points for small entities workable, and how should a small entity be defined?
- Is the reporting framework operationally feasible, and what will implementation cost?
Sources
- AMLA - consultation on the draft RTS on the risk profile of obliged entities in the non-financial sector (13 Jul - 27 Sep 2026)
- AMLA - consultation paper on the draft RTS under Art. 40(2) AMLD6, non-financial sector (13 Jul 2026)
- AMLA - Annexes I and II: data points per activity, draft RTS under Art. 40(2) AMLD6
- AMLA - press release: harmonised risk assessments in the non-financial sector (13 Jul 2026)
- AMLA - public hearing on the draft RTS, non-financial sector (10 Sep 2026)
- AMLA - explainer for the non-financial sector, with the 2026 consultation calendar (9 Feb 2026)
Framework blocks it lands on
This instrument on the dashboard, with the other instruments and the framework: Open on the dashboard