AMLA hands the EU a directly binding customer due diligence rulebook

What happened

The EU anti-money laundering package handed AMLA, the EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism, a demanding drafting schedule. It called for the authority to finalise its regulatory technical standards (RTS) and most of its implementing technical standards (ITS) by July 2026. Most of AMLA’s 23 mandates were due by 10 July 2026. The deadline for AMLA to deliver its technical standards package fell on 10 July 2026, with the customer due diligence (CDD) RTS as the centrepiece.

That standard sits under Article 28(1) of the AMLR, the Anti-Money Laundering Regulation. It defines, in binding terms, the information necessary to perform customer due diligence across the EU. AMLA consulted on the draft publicly from 9 February 2026 to 8 May 2026 and held a public hearing on it. According to AMLA, the drafting aimed at legal clarity, proportionality, a risk-based approach, and applicability to all categories of obliged entities, with attention to the non-financial sector.

Separately, AMLA issued a consultation paper on 2 July 2026 on draft ITS specifying the format for reporting suspicions and providing transaction records under the AMLR.

Why it matters

The instrument type matters more than any single drafting detail. Once the European Commission adopts an RTS, it applies directly across member states. No transposition step follows, which means no national legislator to soften the text and no interpretation gap for an obliged entity to sit inside.

That is a change in posture for firms trained on directives. A directive arrives with a transposition window and a national flavour, and compliance teams have learned to wait for the local regulator’s implementing guidance before touching a procedure. An RTS removes that waiting room. What the final text says about the information necessary for CDD is what supervisors across the EU will expect to find in the file.

The scope signal is the second thing to read. AMLA says it built the draft for all categories of obliged entities, with attention to the non-financial sector. Accountants, estate agents, notaries, and dealers in high-value goods have worked from a lighter and more fragmented rulebook than banks. This one is written for them too.

Practitioner angle

• Read the draft CDD RTS against your onboarding and periodic refresh procedures now, not after the Commission adopts it. Map each requirement to the procedure step and the data field that is supposed to satisfy it.
• Identify where your identity-verification evidence falls short of what the draft specifies. The usual weak points are document quality standards, verification of the natural person behind a legal entity, and the evidence retained to support a source of funds assertion.
• Non-financial obliged entities should not treat this as a bank rulebook. If you sit in an accountancy firm, a notary practice, or an estate agency, run the same gap analysis a bank would run.
• Track AMLA’s 2 July 2026 ITS consultation on the format for reporting suspicions and providing transaction records. Reporting format is a data problem, and a data problem lands on your systems team, not your policy team.
• Watch the Commission adoption step. That is the moment a draft you are reading becomes a rule you are supervised against.

The single most important action: run a documented gap analysis of your CDD file standard against the draft RTS this quarter, and put the gaps in front of your board while the text is still a draft.