Keltes

The AMLR timeline: the dates in the text

7 October 2026, Keltes

Every date below is quoted from Regulation (EU) 2024/1624 or from Directive (EU) 2024/1640. Where the texts give no date, neither do we.

Entry into force and application

The Anti-Money Laundering Regulation (AMLR, Regulation (EU) 2024/1624) entered into force on the twentieth day after its publication in the Official Journal of the European Union.1 Directive (EU) 2024/1640 refers to it as published in the Official Journal on 19 June 2024.2 The Regulation does not print its own date of entry into force, but it dates the Commission's power to adopt delegated acts from 9 July 2024.3

The Regulation applies from 10 July 2027. For two kinds of obliged entity, football agents and professional football clubs in respect of certain transactions, it applies from 10 July 2029.45 It is binding in its entirety and directly applicable in all Member States.6

The companion Directive (EU) 2024/1640 works differently. It repeals Directive (EU) 2015/849 with effect from 10 July 2027.7 Member States must bring into force the national measures needed to comply with it by 10 July 2027, with different dates for some articles: 10 July 2025 for Article 74, 10 July 2026 for Articles 11, 12, 13 and 15, and 10 July 2029 for Article 18.8

What AMLA was to deliver by 10 July 2026

The Regulation gives the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) a first set of deadlines on 10 July 2026. They include guidelines on what entities should take into account, given their business, risks, complexity and size, when deciding on the extent of their internal policies, procedures and controls, in particular the staff allocated to the compliance functions;9 guidelines on the minimum content of the business-wide risk assessment;10 guidelines on the risk variables and risk factors to consider when entering into business relationships or carrying out occasional transactions;11 guidelines on ongoing monitoring;12 and draft regulatory technical standards on group-wide policies, procedures and controls.13

That date has passed. Whether AMLA has issued each of these instruments is a question for its own publications, which this article does not cover.

Deadlines on and after 10 July 2027

A second set of AMLA deadlines falls on 10 July 2027, the day the Regulation applies. It includes guidelines on outsourcing,14 guidelines on the risks, trends and methods involving geographical areas outside the Union, which AMLA must review at least every two years,15 and guidelines on indicators of suspicious activity or behaviours, to be updated periodically.16

Member States have deadlines of their own. By 10 October 2027 they must notify the Commission of the exemptions granted under Article 2(2) and (3) of Directive (EU) 2015/849 that are in place on 10 July 2027.17

Where, on 10 July 2027, certain legal entities or arrangements created, administered or with a trustee outside the Union own real estate, their beneficial ownership information must be submitted to the central register with a justification by 10 January 2028. This does not apply to those that acquired real estate in the Union before 1 January 2014, and Member States may set an earlier date on the basis of risk.18

Companies may no longer issue bearer shares and must convert, immobilise or deposit existing ones by 10 July 2029, subject to the exceptions in the same paragraph. Voting and distribution rights on existing bearer shares not dealt with by then are automatically suspended until they are, and shares still not dealt with by 10 July 2030 are cancelled.19

Two dates concern the Commission's own review. By 10 July 2030 it must report on whether to change certain thresholds and scope rules, including the 25 % ownership threshold for beneficial ownership and the limit for large cash payments.20 By 10 July 2032, and every three years after that, it must review the application of the Regulation.21

What the text does not date

Some dates people expect on a timeline are not in these texts. Neither text says when Luxembourg or Belgium will adapt the parts of their national AML laws that the Regulation now covers, and the transposition dates above concern the Directive only. For a compliance officer, the dates that matter most are these: the obligations bind from 10 July 2027, or 10 July 2029 for the football sector,4 and several AMLA guidelines on how to meet them were due a year earlier.910

About this article

This article is general information about the texts it quotes, as they stood when it was written. It is not legal advice and does not replace advice on your own entity's situation. The list of deadlines is a selection; the Regulation sets others, each in the article concerned.

Sources

  1. AMLR Art. 90, first paragraph This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. ↑
  2. Directive (EU) 2024/1640, Art. 75 Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing ( OJ L, 2024/1624, 19.6.2024, ELI: http://data.europa.eu/eli/reg/2024/1624/oj ). ↑
  3. AMLR Art. 85(2) The power to adopt delegated acts referred to in Articles 29, 30, 31, 34, 43, 52 and 68 shall be conferred on the Commission for an indeterminate period of time from 9 July 2024. ↑
  4. AMLR Art. 90, second paragraph It shall apply from 10 July 2027, except in relation to obliged entities referred to in Article 3, points (3)(n) and (o), to which it shall apply from 10 July 2029. ↑
  5. AMLR Art. 3, point (3)(n) and (o) (n) football agents; (o) professional football clubs in respect of the following transactions: ↑
  6. AMLR Art. 90, third paragraph This Regulation shall be binding in its entirety and directly applicable in all Member States. ↑
  7. Directive (EU) 2024/1640, Art. 77 Directive (EU) 2015/849 is repealed with effect from 10 July 2027. ↑
  8. Directive (EU) 2024/1640, Art. 78(1) Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive by 10 July 2027. They shall immediately inform the Commission thereof. By way of derogation from the first subparagraph, Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with Article 74 by 10 July 2025, with Articles 11, 12, 13 and 15 by 10 July 2026 and with Article18 by 10 July 2029. ↑
  9. AMLR Art. 9(4) By 10 July 2026, AMLA shall issue guidelines on the elements that obliged entities should take into account, based on the nature of their business, including its risks and complexity, and their size, when deciding on the extent of their internal policies, procedures and controls, in particular as regards the staff allocated to the compliance functions. ↑
  10. AMLR Art. 10(4) By 10 July 2026, AMLA shall issue guidelines on the minimum requirements for the content of the business-wide risk assessment drawn up by the obliged entity pursuant to paragraph 1 ↑
  11. AMLR Art. 20(3) By 10 July 2026, AMLA shall issue guidelines on the risk variables and risk factors to be taken into account by obliged entities when entering into business relationships or carrying out occasional transactions. ↑
  12. AMLR Art. 26(5) By 10 July 2026, AMLA shall issue guidelines on ongoing monitoring of a business relationship and on the monitoring of the transactions carried out in the context of such relationship. ↑
  13. AMLR Art. 16(4) By 10 July 2026, AMLA shall develop draft regulatory technical standards and submit them to the Commission for adoption. Those draft regulatory technical standards shall specify the minimum requirements of group-wide policies, procedures and controls ↑
  14. AMLR Art. 18(8) By 10 July 2027, AMLA shall issue guidelines addressed to obliged entities on: (a) the establishment of outsourcing relationships, including any subsequent outsourcing relationship, in accordance with this Article, their governance and procedures for monitoring the implementation of functions by the service provider and in particular those functions that are to be regarded as critical; ↑
  15. AMLR Art. 32(1) and (2) By 10 July 2027, AMLA shall issue guidelines defining the money laundering and terrorist financing risks, trends and methods involving any geographical area outside the Union to which obliged entities are exposed. AMLA shall take into account, in particular, the risk factors listed in Annex III. Where situations of higher risk are identified, the guidelines shall include enhanced due diligence measures that obliged entities shall consider applying to mitigate such risks. 2. AMLA shall review the guidelines referred to in paragraph 1 at least every 2 years. ↑
  16. AMLR Art. 69(5) By 10 July 2027, AMLA shall issue guidelines on indicators of suspicious activity or behaviours. Those guidelines shall be periodically updated. ↑
  17. AMLR Art. 7(4) By 10 October 2027, Member States shall notify to the Commission the exemptions granted pursuant to Article 2(2) and (3) of Directive (EU) 2015/849 in place on 10 July 2027. ↑
  18. AMLR Art. 67(7) Where, on 10 July 2027, legal entities created outside the Union or legal arrangements administered outside the Union or whose trustee or person holding an equivalent position in a similar legal arrangement resides or is established outside the Union own, whether directly or through intermediaries, real estate, the beneficial ownership information of those legal entities and legal arrangements shall be submitted to the central register and accompanied by a justification for that submission by 10 January 2028. However, the first subparagraph shall not apply to legal entities or legal arrangements that have acquired real estate in the Union prior to 1 January 2014. Member States may decide, on the basis of risk, that an earlier date applies and notify the Commission thereof. ↑
  19. AMLR Art. 79(3) Companies shall be prohibited from issuing bearer shares, and shall convert all existing bearer shares into registered shares, shall immobilise them within the meaning of Article 2(1), point (3), of Regulation (EU) No 909/2014, or deposit them with a financial institution by 10 July 2029. However, companies with securities listed on a regulated market or whose shares are issued as intermediated securities either through immobilisation within the meaning of Article 2(1), point (3), of that Regulation or through a direct issuance in dematerialised form within the meaning of Article 2(1), point (4), of that Regulation shall be permitted to issue new and maintain existing bearer shares. For existing bearer shares that are not converted, immobilised or deposited by 10 July 2029, all voting rights and rights to distribution attached to those shares shall be automatically suspended until their conversion, immobilisation or deposit. All such shares not converted, immobilised or deposited by 10 July 2030 shall be cancelled, leading to a share capital decrease of the corresponding amount. ↑
  20. AMLR Art. 88 By 10 July 2030, the Commission shall submit reports to the European Parliament and to the Council assessing the necessity and proportionality of: (a) lowering the 25 % threshold for the identification of beneficial ownership of legal entities through ownership interest; (b) extending the scope of high-value goods to include high-value garments and accessories; (c) extending the scope of the threshold-based disclosures under Article 74 to cover the sale of other goods, of introducing harmonised formats for the reporting of those transactions based on the usefulness of those reports for FIUs, and of extending the scope of information collected from persons trading in free-trade zones; (d) adjusting the limit for large cash payments. ↑
  21. AMLR Art. 87 By 10 July 2032, and every 3 years thereafter, the Commission shall review the application of this Regulation and submit a report to the European Parliament and to the Council. ↑
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