AMLA Home-Host Hearing: What Cross-Border AML Teams Should Do After 28 May

ByOfficer

Last updated: May 2026

On 28 May 2026, AMLA held its public hearing on the draft Regulatory Technical Standards for home-host supervisory cooperation under Article 46(4) of Directive (EU) 2024/1640 (AMLD). The hearing ran from 14:00 to 16:00 CET and was the sole channel for stakeholder input on this particular consultation. No written submissions were accepted. If your group operates through subsidiaries in more than one EU Member State and you did not participate, the window to influence this framework has closed. What remains open is the operational preparation, and that is where teams should focus now.

This article does not repeat the content of our pre-hearing guide from 14 May, which covered the draft RTS structure, scope, and consultation questions in detail. This piece focuses on what the AMLA home-host hearing means at this stage: what the open points are, what teams commonly get wrong in their preparation, and what comes next in the regulatory pipeline.

Related reading: AMLA Home-Host Cooperation RTS: 28 May Hearing Guide for Cross-Border AML Teams

What Happened on 28 May and What Is Still Pending

The 28 May hearing was one of four AMLA public hearings held across two days. On 27 May, AMLA held hearings on draft ITS for FIU-to-FIU information exchanges and on draft ITS for FIU and AMLA reporting to the European Public Prosecutor’s Office (EPPO). On 28 May, the morning session (10:00 to 12:00 CET) covered draft Guidelines on business-wide risk assessment under Article 10(4) of Regulation (EU) 2024/1624 (AMLR). The afternoon session covered the home-host supervisory cooperation RTS.

At the time of writing, AMLA has not published a transcript, recording, summary of feedback, or any post-hearing statement from the 28 May sessions. That is expected. AMLA’s standard process is to consider stakeholder input internally, potentially revise the draft, and submit the final RTS to the European Commission for adoption as a Commission Delegated Regulation. No timeline for post-hearing publication has been announced. Teams should monitor the AMLA public consultations page for any feedback statement or revised draft.

The absence of published hearing outcomes does not change what compliance teams need to do. The draft RTS text is public. The direction of travel is clear. Waiting for a final version before starting internal preparation is the most common and most costly mistake I see in cross-border AML governance.

The AMLA Home-Host Hearing in Context: Four Hearings, One Framework

Teams that treat the home-host cooperation RTS in isolation miss the bigger picture. The four hearings on 27-28 May covered four instruments that will operate together once the AML package takes effect:

  • ITS on FIU-to-FIU information exchanges (heard 27 May)
  • ITS on FIU and AMLA reporting to the EPPO (heard 27 May)
  • Guidelines on business-wide risk assessment under Article 10(4) AMLR (heard 28 May morning)
  • RTS on home-host supervisory cooperation under Article 46(4) AMLD (heard 28 May afternoon)

The business-wide risk assessment (BWRA) guidelines are directly relevant to cross-border groups because they define minimum requirements for how obliged entities assess the risks arising from their business model, customers, products, delivery channels, and geographical exposure. That assessment feeds the supervisory risk assessment your home and host supervisors will perform under Article 40 of the AMLD. Under the draft home-host RTS, those supervisory risk assessments are among the categories of information that supervisors must proactively share with each other.

The connection matters operationally. If your group’s BWRA does not adequately reflect the risk profile of each subsidiary’s jurisdiction, the host supervisor’s assessment will diverge from the home supervisor’s assessment. Under the draft RTS, that divergence will surface quickly through mandatory information exchange. Groups that produce a single, headquarters-driven BWRA without subsidiary-level granularity will find their supervisors asking different questions and reaching different conclusions about the same group.

Unlike the home-host RTS, the BWRA guidelines consultation accepts written responses via EU Survey until 15 July 2026. Cross-border groups still have time to submit on that instrument.

Open Points Where Industry Positions Likely Diverge

Having reviewed the draft RTS and the seven consultation questions, I see three areas where industry feedback during the hearing was most likely to concentrate. These are the points where the draft leaves operational questions unanswered or makes policy choices that create friction for groups.

The notification-based disclosure regime under proposed Article 9 is the most contentious. AMLA chose to allow supervisors to share information received under the Article 46 framework with other EU supervisors without prior consent, subject only to notification. AMLA’s consultation paper considered a consent-based alternative and rejected it as too burdensome for effective supervisory cooperation. Industry positions split here. Institutions with centralised compliance models generally prefer consent-based sharing because it preserves visibility and control over how information about their group flows through the supervisory system. Institutions with decentralised models may be less concerned, but face the separate risk that information about a subsidiary in one jurisdiction reaches a supervisor in another jurisdiction without the group compliance function knowing about it until after the fact.

The cross-border inquiry framework under proposed Article 7 raises practical questions about procedural safeguards. A requesting supervisor can conduct an inquiry directly in another Member State with the host supervisor’s facilitation. The draft requires the host supervisor to “take reasonable steps” to facilitate access and help overcome language, procedural, or operational barriers. What constitutes “reasonable steps” is not defined. For a subsidiary facing an on-site visit by a foreign AML supervisor facilitated by its own national authority, the gap between the draft wording and operational reality is where confusion sits.

The scope boundary between Article 46 (groups with subsidiaries) and Article 47 (branch-only operations) creates complexity for groups that use both structures across different Member States. A single group might have a subsidiary in one Member State and a branch in another. Two different cooperation frameworks would apply to the same group’s different establishments. Whether supervisors will coordinate those two frameworks in practice, or whether groups will face inconsistent engagement depending on the establishment type, is an operational question the draft RTS does not resolve.

What Cross-Border AML Teams Get Wrong at This Stage

Three recurring errors stand out.

First, treating the RTS timeline as distant. The AMLR applies from 10 July 2027. The AMLD must be transposed by Member States. The draft RTS, once adopted by the Commission and published in the Official Journal, will be directly applicable. That sequence looks like it gives teams time. It does not. The RTS governs how your supervisors will cooperate. Your ability to respond efficiently to supervisory requests, cross-border inquiries, and information-sharing depends on internal processes you need to build now: a group supervisory map, escalation protocols for multi-jurisdictional requests, and coordination procedures between your subsidiary compliance functions.

Second, assuming this only affects banks. AMLA adopted a fully horizontal approach. The draft RTS covers supervisors of all obliged entities in groups operating across borders, financial and non-financial. Networks and partnerships with shared compliance control in the non-financial sector fall within scope under Article 46(6) of the AMLD. This catches accountancy networks, real estate groups, and other non-financial sector structures that most AML governance frameworks have not been designed to accommodate.

Third, confusing the home-host cooperation RTS with the AML/CFT supervisory college framework. The college framework under Articles 49 and 50 of the AMLD is a separate instrument. Draft RTS under Articles 49(14) and 50(13) are expected from AMLA separately. Where a college exists, it takes precedence for matters it covers. Where no college exists, the home-host cooperation RTS is the primary cooperation mechanism. Many groups fall into the second category, especially smaller cross-border groups and those in the non-financial sector. If you do not know whether your group will have an AML/CFT supervisory college under the new framework, that is a gap in your preparation.

Governance Actions for Groups: What to Start Now

Regardless of what feedback emerged during the hearing, the core architecture of the draft RTS is unlikely to change materially. AMLA has signalled its position on the notification-based disclosure regime, the cross-border inquiry framework, and the horizontal scope. Detailed wording may shift, but the governance implications for cross-border groups remain the same.

I see five actions that group AML teams should initiate now rather than waiting for the final text.

Map your group’s supervisor-to-supervisor cooperation landscape. For each subsidiary in a different EU Member State, identify which national AML/CFT supervisor oversees that entity. Determine whether an AML/CFT supervisory college is likely to be established for your group under Articles 49 or 50 of the AMLD. If not, your supervisors will rely on the home-host cooperation RTS as their primary coordination tool. This map is the foundation for everything else.

Build an internal protocol for responding to cross-border supervisory requests. Under the draft RTS, supervisors will use the template in Annex I to submit cooperation requests, and host supervisors may conduct inquiries on behalf of requesting supervisors or facilitate direct access for foreign supervisors. Your group compliance function needs a clear escalation path: who receives notification, who coordinates the response, and how subsidiary-level compliance teams interact with head-office functions during a cross-border inquiry.

Review your group-wide AML/CFT policies for consistency across jurisdictions. The draft RTS requires supervisors to exchange views on common supervisory approaches and coordinate follow-up measures. If your group policies produce materially different risk assessments or control frameworks across subsidiaries, the gap will become visible when supervisors compare notes. Aligning internal policies is cheaper than explaining divergence after the fact.

Assess the BWRA methodology at subsidiary level. The draft BWRA guidelines under Article 10(4) AMLR require a risk assessment that reflects each entity’s specific business model, customers, products, delivery channels, and geographical exposure. For cross-border groups, a single group-level BWRA that does not disaggregate risk by subsidiary and jurisdiction will not satisfy the standard. Begin building subsidiary-level BWRA components now, using the four minimum requirements proposed in the AMLA draft guidelines as the structure.

Identify information-exchange restrictions in each jurisdiction. Proposed Article 9 allows EU supervisors to share information within the supervisory system with notification only. But data protection rules, national banking secrecy provisions, and legal professional privilege (excluded under Article 70(2) AMLR) may create friction in specific jurisdictions. If your group has entities in Member States where national law restricts certain types of information exchange, document those restrictions now so your compliance function can anticipate where supervisory cooperation may encounter barriers.

What Comes Next in the AMLA Pipeline

The home-host cooperation RTS is one piece of a much larger AMLA regulatory production programme. Understanding what else is coming helps teams prioritise.

AMLA must develop separate draft RTS under Articles 49(14) and 50(13) of the AMLD for AML/CFT supervisory colleges. Those instruments will govern the composition, functioning, and coordination procedures for colleges overseeing the largest and most complex cross-border groups. No consultation paper for those RTS has been published yet.

Separately, Article 47 of the AMLD covers cooperation for branch-only and agent-based cross-border operations. The cooperation framework for those structures is distinct from the Article 46 RTS and will need its own implementing measures.

AMLA’s reporting package for the first direct supervision selection cycle was published on 12 May 2026. Under the AMLA Regulation (Regulation (EU) 2024/1620), AMLA will directly supervise certain high-risk obliged entities starting from 2028. The identification methodology and reporting templates for provisionally eligible entities are now public. Groups that may fall within AMLA’s direct supervision scope face a different governance challenge altogether: their primary AML supervisor shifts from the national authority to AMLA itself.

The BWRA guidelines consultation under Article 10(4) AMLR remains open for written submissions until 15 July 2026 via EU Survey. This is the instrument that defines the minimum requirements for risk assessment at entity level. For cross-border groups, the BWRA standard directly affects what supervisors will expect to see when they perform their own risk assessments and exchange them under the home-host cooperation framework.

The Home-Host RTS and Group-Wide AML Policy Alignment

One dimension the pre-hearing preview did not cover in depth is the interaction between the draft RTS and group-wide AML/CFT policies under the new framework.

Article 16 of the AMLR requires groups to implement group-wide AML/CFT policies, procedures, and controls. These must be applied by all entities and branches within the group, including subsidiaries in other Member States. The home-host cooperation RTS specifies how supervisors will coordinate their oversight of whether those group-wide policies are actually implemented consistently.

The real problem starts when a home supervisor is satisfied with the group-wide policy but a host supervisor finds that a subsidiary in its jurisdiction is not implementing the policy effectively. Under the proposed common approaches framework in Article 8 of the draft RTS, supervisors must exchange views on such divergences and may agree on coordinated follow-up, including coordinated enforcement measures. If one supervisor agrees to a common approach and then does not follow through, the other may refer the failure to AMLA.

For group compliance teams, this means your group-wide AML policy is no longer just an internal governance document. It becomes the benchmark against which multiple supervisors will measure your subsidiaries, and those supervisors are now required to compare notes. If the policy says one thing and the subsidiary does another, the gap will surface through the cooperation framework before your own internal audit catches it.

I have seen groups draft group-wide AML policies at headquarters without adequate subsidiary input, leaving local compliance teams to fill the implementation gaps informally. Under the new framework, those informal workarounds become supervisory risk because the host supervisor will assess implementation against the stated policy and share its findings with the home supervisor. Get ahead of this by conducting a group-wide policy implementation review now.

Frequently Asked Questions

Has AMLA published the results or a summary from the 28 May hearing?

Not at the time of writing. AMLA typically considers stakeholder input internally before publishing any feedback statement or revising the draft. There is no announced timeline for post-hearing publication. Monitor the AMLA public consultations page for updates.

Can I still submit feedback on the home-host cooperation RTS?

AMLA described the 28 May hearing as the designated channel for stakeholder input on this specific RTS. No written submissions were accepted, and no EU Survey link was provided for this consultation. The feedback window has closed unless AMLA announces an additional submission route.

Can I still submit feedback on the BWRA guidelines?

Yes. The BWRA guidelines consultation under Article 10(4) AMLR accepts written responses via EU Survey until 15 July 2026. The 28 May hearing supplemented but did not replace the written consultation.

When will the home-host cooperation RTS become law?

After considering hearing feedback, AMLA will finalise the draft and submit it to the European Commission for adoption as a Commission Delegated Regulation. The consultation paper does not specify a target date for Commission submission. Once adopted and published in the Official Journal, the RTS will be directly applicable in all Member States. The broader AML package timeline provides context: the AMLR applies from 10 July 2027, and Member States must transpose the AMLD by its respective deadline.

My group has both subsidiaries and branches in different Member States. Which cooperation framework applies?

Two frameworks apply to different parts of your group structure. Subsidiaries and other group members fall under Article 46 of the AMLD, covered by this draft RTS. Branches, agents, and distributors fall under Article 47 of the AMLD, which has its own cooperation provisions. Groups with mixed structures will need to track both frameworks and understand where the boundaries sit.

Does the draft RTS require my institution to do anything directly?

The draft RTS governs cooperation between supervisors, not obligations on obliged entities directly. But supervisory cooperation generates supervisory requests, cross-border inquiries, and information-sharing that obliged entities must respond to. Your ability to respond efficiently depends on internal preparation: knowing which supervisors oversee which parts of your group, having escalation protocols for cross-border requests, and ensuring subsidiary compliance functions can coordinate with head-office teams.

Is the non-financial sector really in scope?

Yes. AMLA adopted a fully horizontal approach. Article 46(6) of the AMLD extends the cooperation framework to non-financial sector supervisors responsible for obliged entities in structures sharing common ownership, management, or compliance control, including networks and partnerships. While non-financial supervisors are not formally required to apply the RTS procedures, AMLA encourages voluntary adoption.

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Key Takeaways

  • AMLA held its public hearing on the draft home-host supervisory cooperation RTS on 28 May 2026 (14:00 to 16:00 CET). No post-hearing outcomes, transcript, or feedback statement have been published yet.
  • The hearing was the sole stakeholder input channel for this RTS. No written submissions were accepted. The feedback window has closed.
  • The 28 May hearing was one of four AMLA hearings held on 27-28 May, covering FIU exchanges, EPPO reporting, business-wide risk assessment guidelines, and home-host cooperation. These instruments will operate together under the new AML package.
  • The BWRA guidelines consultation under Article 10(4) AMLR remains open for written responses until 15 July 2026. Cross-border groups should submit on the BWRA standard because it directly feeds the supervisory risk assessments exchanged under the home-host framework.
  • Groups should start internal preparation now: map the supervisor-to-supervisor cooperation landscape, build escalation protocols for cross-border inquiries, and align group-wide AML policies with subsidiary-level implementation.
  • Separate AMLA instruments are still expected for AML/CFT supervisory colleges (Articles 49 and 50 AMLD) and for branch-only cross-border cooperation (Article 47 AMLD).
  • Group-wide AML policies under Article 16 AMLR will become the benchmark against which multiple supervisors measure subsidiaries. Gaps between the stated policy and actual implementation will surface through the cooperation framework.

Sources and References

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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