AMLA consultation – Draft RTS on Business Relationships, Occasional & Linked Transaction under article 19(9) AMLR

Accountancy Europe has submitted comments in response to the AMLA consultation on draft Regulatory Technical Standards on criteria for business relationships, occasional transactions and linked transactions under Article 19(9) of Regulation (EU) 2026/1624.

Accountancy Europe identifies several key concerns in the submission, in particular:

Operational challenges and need for sector-specific guidance

We foresee significant operational challenges in implementing this draft RTS, as it is primarily designed for transaction-based financial institutions and does not adequately reflect service-based professions such as accountancy and audit.

We recommend greater flexibility, clearer recognition of sector differences, and the introduction of sector-specific guidance and illustrative scenarios. We also stress the importance of sufficient transitional arrangements and timely availability of Level 2 and Level 3 measures to support effective implementation.

Definition of business relationships – limited clarity for professional services

We do not consider the criteria in Article 2 of the draft RTS to be sufficiently clear or effective in identifying “business relationships,” particularly in the context of professional services such as accountancy practices. In its current form, the RTS does not fully reflect how such services operate in practice and thus is of limited applicability.

Professional services are typically provided within a formalised engagement framework, which defines the scope of work and may involve a degree of interaction over time. As a result, even where services appear to be provided on a one-off basis, they may nonetheless involve elements characteristic of a business relationship.

Linked transactions criteria overly prescriptive and financial-sector oriented

We do not consider the criteria in Article 3 to be fully effective, as they are primarily designed for the banking sector and are not readily applicable to audit and accountancy practices. The framework is overly prescriptive and risks a checklist-driven approach rather than a meaningful risk-based assessment.

We recommend revising Article 3 to explicitly allow for a risk-based and client-specific assessment, clarifying that criteria should be applied only “where relevant” for the type of business, and ensuring a clearer distinction between financial and non-financial obliged entities.