AMLR 2024
AMLR 2024, 2025 and 2026: what has changed
A dated timeline of the milestones that already happened, and the ones still to come.
Talk to an expertSearches for “AMLR 2024” and “AMLR 2025” usually come from people who want to know what is already in force. The honest answer: very little of the AMLR is. But the dates around it matter.
2024: the package is adopted
The AMLR (Regulation (EU) 2024/1624) was signed on 31 May 2024. It entered into force on the twentieth day after publication in the Official Journal and applies from 10 July 2027. The same package included Directive (EU) 2024/1640 and Regulation (EU) 2024/1620, which set up the Anti-Money Laundering Authority.
Some provisions did not wait for 2027. Under Article 80(3), Member States had to notify the Commission of existing national cash limits below EUR 10,000 by 10 October 2024.
2025: groundwork
Directive 2024/1640 required national measures for its Article 74 (access to beneficial ownership information) by 10 July 2025. Nothing in the AMLR itself fell due this year. AMLA was still being built, and it opened its first public consultation in December 2025, according to the AMLA website.
2026: the secondary rules take shape
Several things were due by 10 July 2026 under the AMLR itself, including AMLA guidelines on the content of the business-wide risk assessment (Article 10(4)) and draft technical standards on group-wide requirements (Article 16(4)). AMLA consulted on both drafts from April 2026, as the FIAU reported; the risk assessment consultation closed on 15 July 2026, after the 10 July date. Directive 2024/1640 Articles 11, 12, 13 and 15 also had a 10 July 2026 transposition deadline. Check the AMLA website for which texts are final, because a draft is not something to build on.
2027: the big date
10 July 2027 is when the AMLR applies, Member States must have transposed the Directive, and the old Directive (EU) 2015/849 is repealed (Directive 2024/1640, Articles 77 and 78). Football clubs and agents follow on 10 July 2029. According to the AMLA website, 40 obliged entities are selected for direct supervision during 2027 and direct supervision starts during 2028. Under Regulation 2024/1620 these are high-risk financial groups and institutions active in at least six Member States, so most readers will stay with their national supervisor.
Later
Bearer shares must be converted, immobilised or deposited by 10 July 2029 (Article 79(3)).
What to do with this
Mark three dates in your compliance calendar: AMLA’s final guidelines, your country’s transposition law, and 10 July 2027. Our 90-day action plan turns that into tasks.
What this means for you
Not sure which of these dates touch your firm? Put the question in the enquiry form and we will answer in writing, or set up a call if that is easier.
General information, not legal advice.