18 May 2026 — Consultation Response
Accountancy Europe has submitted feedback in response to the consultation carried out by the EU Anti-Money Laundering Authority (AMLA) on draft Regulatory Technical Standards (RTS) on Customer Due Diligence under Article 28(1) of Regulation (EU) 2024/1624.
In its submission, Accountancy Europe highlights the importance of ensuring that the framework remains proportionate, risk-based and workable for non-financial obliged entities, including accountancy service providers.
Accountancy Europe identifies several specific concerns in the submission, in particular:
The RTS remains heavily oriented towards the financial sector, despite its equal applicability to non-financial sectors. For accountancy service providers, whose services are generally relationship-based rather than transaction-driven, this approach is not appropriate and risks creating disproportionate operational burden.
We recommend clarifying that these requirements should be applied proportionately to the nature of the service provided, allowing obliged entities to rely on broader knowledge of the client and their activities rather than requiring transaction-specific information in all cases.
The RTS sets out detailed CDD measures which leaves limited scope for the consideration of the sector specific risks and the exercise of judgement. This risks undermining the AMLR’s objective of enabling a proportionate and effective application of AML/CFT measures.
We recommend that where possible in line with the Level 1 legislation, AMLA introduce clearer and more explicit risk-sensitive language throughout the RTS. The RTS should clarify how obliged entities may adjust the scope, intensity, and frequency of measures based on the assessed ML/TF risk, including by explicitly allowing for the exercise of professional judgement and consideration of sector-specific risks.
The requirement to update customer due diligence information for existing high-risk customers within a short timeframe may create disproportionate operational burdens for smaller firms with limited compliance resources. Accountancy Europe recommends introducing explicit proportionality considerations and allowing greater flexibility regarding implementation timelines.
Certain RTS requirements may generate significant compliance costs, particularly for smaller firms and non-financial obliged entities. Accountancy Europe recommends that AMLA ensure that the RTS remain proportionate, operationally feasible and appropriately balanced against their expected AML/CFT benefits.
