AMLA Simplified Due Diligence Roundtables: Apply by 18 October

On 2 October 2026 the Anti-Money Laundering Authority (AMLA) opened a call for expressions of interest in sectoral roundtables on simplified customer due diligence (SDD), with applications due by 18 October 2026 at 23:59 CEST. The discussions will feed own-initiative AMLA simplified due diligence guidelines under Article 54 of Regulation (EU) 2024/1620 (the AMLA Regulation, or AMLAR), and AMLA says it particularly wants to hear from the non-financial sector and from sectors that face specific challenges in applying customer due diligence.

The call came two days after the date on AMLA’s final report on the draft regulatory technical standards (RTS) on customer due diligence under Article 28(1) of Regulation (EU) 2024/1624 (the AMLR). That report, dated 30 September 2026, records that AMLA found no way to simplify SDD beyond what Article 33 AMLR already allows without effectively creating exemptions, and that it intends to keep engaging stakeholders, in particular the non-financial sector, on whether additional guidance on SDD is warranted. I read the roundtables as the follow-through on that sentence.

For an obliged entity or a trade association, the useful question is what kind of evidence can move the guidelines. Article 33 fixes the menu of reductions, and the call states that the guidelines will stay within the applicable legal framework without creating exemptions from AMLR requirements. What AMLA asks participants to bring is anonymised, recurring situations with their prevalence, plus the measures that keep the residual risk low. That material takes longer to assemble than a sixteen-day application window.

Related reading: AMLA Final RTS: CDD Data, Linked Transactions and Group-Wide Rules

Key dates for the AMLA simplified due diligence roundtables

Every date below comes from AMLA’s call for expressions of interest and news announcement of 2 October 2026, except the last row, which comes from Article 90 AMLR.

The written input is the step most likely to compress. AMLA has not yet set its deadline, and the indicative roundtable period opens on 9 November, ten days after the 30 October outcome date.

Own-initiative guidelines under Article 54 AMLAR: what the label carries

Article 54(1) AMLAR lets AMLA issue guidelines and recommendations addressed to supervisory authorities, supervisors, financial intelligence units (FIUs) or obliged entities, to establish consistent supervisory practice and to ensure the common, uniform and consistent application of Union law. The call describes the SDD guidelines as own-initiative guidelines under that article. No AMLR provision mandates them, which sets them apart from the guidelines the AMLR requires by a fixed date, such as those on risk variables and risk factors under Article 20(3) and on ongoing monitoring under Article 26(5), both due by 10 July 2026. The call gives no adoption date for the SDD guidelines.

Article 54 then shapes the instrument in three ways.

• Consultation. Article 54(2) requires open public consultations where appropriate, with an analysis of costs and benefits. Both the call and the news announcement confirm a formal public consultation on the draft guidelines will follow, and both state that the roundtables do not constitute one.
• Compliance. Under Article 54(3), supervisory authorities, supervisors, FIUs and obliged entities shall make every effort to comply. Each supervisory authority, supervisor or FIU has two months from issuance to confirm whether it complies or intends to comply, and AMLA publishes the fact of non-compliance. Obliged entities report on their own compliance only where the guideline itself requires it.
• Succession. Article 54(5) keeps guidelines issued by the EBA under Directive (EU) 2015/849 applicable, provided they are still relevant, until AMLA’s guidelines on the same subject start to apply, and requires AMLA to provide a suitable transition period.

Supervisors record their compliance decisions in different ways; our note on BaFin’s AMLA guidelines overview table shows how one national authority now publishes that status.

The succession rule matters most for current practice. The EU-level SDD guidance in force today is the EBA’s Guidelines on ML/TF risk factors (EBA/GL/2021/02, as amended), issued under Articles 17 and 18(4) of Directive (EU) 2015/849 and still listed by AMLA among the EBA instruments that remain applicable. Article 17 of that Directive directed the European Supervisory Authorities to address their SDD guidelines to competent authorities and to credit and financial institutions. Notaries, estate agents, accountants and the rest of the non-financial obliged population had no equivalent EU-level SDD guidance under that article.

Why the final CDD RTS handed SDD back to guidelines

AMLA consulted on its revised draft CDD RTS from 9 February to 8 May 2026, received 325 responses and held a public hearing on 24 March 2026 with more than 1,600 stakeholders. The final report is dated 30 September 2026, and AMLA’s press release of 1 October 2026 says the final draft standards have been submitted to the European Commission. The report records three decisions that frame the roundtables.

First, no new horizontal SDD measures. Article 33(1)(e) AMLR allows any other relevant SDD measure that AMLA identifies under Article 28, so the RTS was the route for adding measure types. AMLA explored simplification beyond the reductions Article 33 already permits and concluded it could not go further without effectively creating exemptions from AMLR obligations, which would exceed its mandate. The report adds that consultation feedback did not identify any additional horizontally applicable SDD measures that could be specified consistently with the AMLR.

Second, no automatic SDD by sector, product or customer category. Several respondents proposed exactly that. AMLA declined because automatic treatment would run counter to the individual risk assessment that Article 20(2) AMLR requires, while amending Article 1 of the draft RTS to stress the application of SDD in situations of low risk.

Third, pooled accounts moved out. Respondents noted that the consultation draft’s provision on SDD for pooled accounts (former Article 22) may not be appropriate across all sectors, and that the sector-specific measures in the draft primarily addressed parts of the financial sector. AMLA concluded that sector-specific measures of this kind would be better addressed through guidelines, to keep the RTS principle-based. The SDD section of the final draft now runs from Article 18 to Article 20 and contains no pooled-account provision.

Reading the second decision as AMLA turning against SDD overlooks the amended Article 1. AMLA’s refusal covers SDD by label. A sector can still apply SDD to a customer whose individual assessment comes out low; the RTS simply will not pre-classify the sector. The roundtables are built around that distinction, because the call asks for situations that may warrant a simplified or proportionate approach together with the low risks and the measures that manage them.

The final draft does fix minimum data for low-risk customers. The comparison below covers the information needed to identify a natural person.

Draft RTS Article 19 then lets a firm identify the beneficial owner in low-risk situations from one listed source and verify from another, and Article 20 sets the minimum purpose-and-nature information. The text remains a draft until the Commission adopts it; once published, it is proposed to apply six months after entry into force, and from 10 July 2029 for football agents and professional football clubs.

The four reductions AMLR Article 33(1) permits, and their limits

Article 33(1) AMLR applies where, taking into account the risk factors in Annexes II and III, the business relationship or transaction presents a low degree of risk. Obliged entities may then apply the measures below, proportionate to the nature and size of the business and to the specific elements of lower risk identified.

Row (b) carries a ceiling that SDD cannot lift. Article 26(2) says the period between updates of customer information “shall not in any case exceed” five years for all customers other than higher-risk customers under the enhanced due diligence section, for whom the limit is one year. Reducing update frequency under Article 33(1)(b) therefore works inside that five-year ceiling. A firm that runs a longer review cycle for its low-risk book today would need to bring it within five years for relationships governed by the AMLR.

The list is also worth reading for what it leaves out. None of the five points reduces the check in Article 20(1)(d) on whether the customer or beneficial owners are subject to targeted financial sanctions, and Article 26(4) keeps a separate duty to verify that regularly, which for credit and financial institutions also runs upon any new designation. Recital 78 AMLR states the principle behind the menu: SDD does not equate to an exemption or absence of CDD measures, and the reduced set should still address all components of the standard procedure. A roundtable scenario that proposes dropping a component entirely asks for something recital 78 places outside SDD.

When AMLR Article 33 switches simplified due diligence off

Article 33(5) lists five situations in which obliged entities shall refrain from applying SDD:

• doubts about the veracity of information provided by the customer or beneficial owner at identification, or inconsistencies in that information;
• the factors indicating lower risk are no longer present;
• monitoring of the customer’s transactions and information collected in the relationship exclude a lower-risk scenario;
• a suspicion of money laundering or terrorist financing;
• a suspicion that the customer, or a person acting for the customer, is attempting to circumvent or evade targeted financial sanctions.

Article 33(4) adds a running test. Obliged entities verify on a regular basis that the conditions for SDD continue to exist, at a frequency commensurate with the nature and size of the business and the risks of the specific relationship. Article 33(2) requires the internal procedures under Article 9 to set out the specific simplified verification measures for each type of lower-risk customer, and requires firms to document decisions to take additional lower-risk factors into account.

An SDD flag set at onboarding and never re-tested does not meet Article 33(4). Point (c) of Article 33(5) also makes the firm’s own monitoring output a reason to leave SDD, which means the reduced scrutiny allowed under Article 33(1)(d) still has to generate enough signal to show when the low-risk scenario stops holding. That circularity deserves a worked answer in any scenario brought to a roundtable, because the call asks participants to identify the associated low risks and the measures needed to manage them.

Annex II lower-risk factors and the evidence behind a low-risk call

Annex II AMLR is a non-exhaustive list of factors and types of evidence of potentially lower risk, in three groups. Customer factors include listed companies subject to disclosure requirements that ensure adequate transparency of beneficial ownership, and public administrations or enterprises. Product and channel factors include low-premium life insurance, financial products that provide defined and limited services to increase access for financial inclusion, and products whose risks are managed by purse limits or ownership transparency, with certain e-money given as the example. Geographical factors cover registration, establishment or residence in Member States or in third countries with effective AML/CFT systems.

Two features of the text limit how far Annex II reaches. Article 33(1) asks for the factors in Annexes II and III to be taken into account together, so a legal entity established in a Member State that is also a personal asset-holding vehicle, an Annex III customer factor, does not become low risk on the strength of its place of establishment. And Article 20(2) requires an individual analysis that draws on the business-wide risk assessment under Article 10 and the risk variables in Annex I, the same provision AMLA cited when it refused sector labels in the RTS.

The legal source of the permission also moves. Under Article 15(1) of Directive (EU) 2015/849, where a Member State or an obliged entity identifies areas of lower risk, that Member State may allow obliged entities to apply SDD, so the permission sits in national law. Directive (EU) 2024/1640 repeals Directive (EU) 2015/849 with effect from 10 July 2027, and from that date Article 33(1) AMLR addresses obliged entities directly: they may apply the listed measures where its conditions are met. My reading is that an SDD perimeter resting today on a national provision transposing Article 15 will need to be re-based on Article 33 and the Annexes, with the Regulation as the source of the permission.

The e-money exemption in Article 19(7) AMLR is a separate mechanism with a separate decision-maker. Supervisors may exempt obliged entities, in full or in part, from the CDD measures in Article 20(1)(a) to (c) for electronic money on the basis of proven low risk, where all four conditions are met: a non-reloadable instrument storing no more than EUR 150, use limited to the issuer’s goods or services or a network of providers, no link to a payment account and no exchange for cash or crypto-assets, and sufficient monitoring by the issuer. The draft CDD RTS specifies the risk factors supervisors consider when setting the extent of that exemption. An e-money issuer bringing a scenario to the roundtables would need to keep the supervisor-granted exemption and its own SDD decision in separate boxes.

Who AMLA wants at the roundtables, and how it will choose

The call welcomes expressions of interest from European-level trade associations and representative bodies, national associations (in particular where no relevant European-level body exists), individual obliged entities able to contribute operational or sectoral experience, and other bodies representing categories of obliged entities. It particularly encourages applications from the non-financial sectors and from sectors facing specific challenges in applying CDD requirements. Nominated representatives should have the practical expertise, seniority and organisational authority to contribute and to represent their organisation’s views.

AMLA will decide the number, scope and composition of the roundtables once it has the expressions of interest, and no roundtable will exceed 25 participants. Selection takes into account, as appropriate:

• representativeness at EU level;
• coverage of different business models, sizes and organisational structures;
• geographic balance and diversity of perspectives;
• representation of less mature or previously underrepresented sectors;
• seniority, relevant practical expertise and experience.

AMLA may also invite representatives of national competent authorities and supervisors as subject-matter experts, or run targeted outreach to fill sectoral, geographic or technical gaps. The meetings are in person in Frankfurt am Main, each lasting between half a day and a full day. English is the only working language, with no interpretation or translation, and all written material must be in English. Participants cover their own travel costs.

The call closes off two assumptions. Submitting an expression of interest creates no right or legitimate expectation to take part and confers no privileged access to AMLA or to the development of the guidelines. Organisations that are not selected keep the regular consultation route, including the public consultation on the draft guidelines. For a comparable AMLA input exercise aimed at one sector, see our note on the AMLA central contact point survey for PSPs and EMIs.

Preparing the expression of interest and the written input

The EU Survey form asks for concise information on the organisation, its sectoral and geographic coverage, its relevant expertise and the practical situations it could contribute. Selected participants then submit short written input in English before their roundtable, on a format AMLA will set later. The call’s list of expected contributions gives that input a natural structure. In the table below, the middle column paraphrases the call; the element names and the right-hand anchors are my own mapping, offered as a working structure.

The confidentiality notice in the call is strict. The expression of interest must not contain customer-level information, personal data on customers, suspicious transaction information, legally privileged material, trade secrets or other confidential case-specific information, and any examples discussed later must be anonymised and shared in line with applicable legal and confidentiality obligations. Prevalence can be shown through aggregates, such as the number of relationships in a product line or its share of the customer book, without touching any of those categories.

An expression of interest that asks for a product or customer type to be taken out of CDD altogether runs into the call’s own boundary, which describes guidelines that operate without creating exemptions from AMLR requirements. A submission built around one of the four Article 33(1) reductions, with its Article 33(5) exit triggers attached, sits inside what the guidelines can address.

Proposals to cut update or scrutiny frequency under Article 33(1)(b) or (d) also touch AMLA’s separate draft guidelines on ongoing monitoring under Article 26(5) AMLR, which cover keeping customer information up to date and the transaction and activity monitoring framework and were consulted on from 3 June to 3 September 2026. The SDD call does not say how the two sets of guidelines will interact.

What governs SDD until AMLA’s guidelines apply

Until 10 July 2027, SDD rests on national laws transposing Article 15 of Directive (EU) 2015/849 and, for credit and financial institutions, on the EBA’s ML/TF risk factor guidelines. Article 54(5) AMLAR keeps those guidelines applicable, provided they are still relevant, until AMLA’s guidelines on the same subject start to apply, with a transition period that AMLA must provide.

From 10 July 2027, Article 33 AMLR applies directly, except for football agents and professional football clubs, for whom the AMLR applies from 10 July 2029. The CDD RTS, once adopted and published in the Official Journal, are proposed to apply six months after entry into force. The SDD guidelines carry no date at all; the public consultation on a draft comes first, and the call does not say when. Our guide to the EU AML package and the 10 July 2027 countdown sets out the wider sequence.

That leaves a period in which the AMLR may already apply while the SDD guidelines are still in draft. The Regulation text, the CDD RTS once they apply and any EBA guidance that remains relevant will carry SDD decisions in that period, which is the practical reason to map current low-risk populations against Article 33 now, whether or not an organisation takes a seat at a roundtable.

Frequently Asked Questions

Can a third-country trade association or a non-EU group entity express interest?

The call names European-level associations, national associations (in particular where no European-level body exists), individual obliged entities and other bodies representing categories of obliged entities. It does not address third-country bodies, and its first selection criterion is representativeness at EU level. Questions about eligibility can go to the call’s contact address, sdd-roundtables@amla.europa.eu, before the deadline.

Can a relationship with a politically exposed person sit in an SDD population if the product itself is low risk?

Article 42(1) AMLR requires, in addition to the Article 20 measures, senior management approval, adequate measures to establish source of wealth and source of funds, and enhanced ongoing monitoring for politically exposed persons. Article 34(1) expressly makes the cases in Articles 36 to 46 enhanced due diligence cases. A relationship or occasional transaction with a PEP therefore falls within the AMLR’s enhanced due diligence regime rather than the simplified due diligence regime in Article 33, irrespective of a lower-risk product characteristic. AMLA’s guidelines under Article 42(2), including on the level of risk associated with particular categories of PEPs, are due by 10 July 2027.

Does SDD work for occasional transactions as well as business relationships?

Article 33(1) opens with “the business relationship or transaction”, and point (c) expressly covers the purpose and intended nature of an occasional transaction. Point (a), the postponed verification, is framed around verifying identity after the business relationship is established, and Article 33(3) speaks of the expected norms for the business relationship. I read the postponement route as tied to business relationships; the other reductions are not limited in the same way.

We apply SDD today under national law. What happens to existing customers on 10 July 2027?

From that date the conditions in Article 33 AMLR govern, so each existing SDD population needs a documented basis in the lower-risk factors of Annex II or in other lower-risk factors recorded under Article 33(2), together with the individual assessment Article 20(2) requires. Separately, draft CDD RTS Article 28 requires documents, data and information on relationships established before the RTS enter into force to be brought in line on a risk-sensitive basis within the Article 26(2) periods, and recital 26 says those one-year and five-year periods start at the RTS’s entry into force.

Can the central beneficial ownership register both identify and verify a low-risk beneficial owner?

Draft RTS Article 19(1) lets a firm identify the beneficial owner or senior managing officials in a low-risk situation from the central register, a business or company register, information provided by the customer, or a reliable independent open source. Article 19(2) allows verification from one of the sources in points (b) to (d) that was not used for identification. The central register appears only in point (a), so on the draft text it can serve for identification while verification comes from a different listed source.

Can customers from a third country qualify for SDD?

Annex II lists registration, establishment or residence in third countries with effective AML/CFT systems, identified by credible sources as having a low level of corruption or other criminal activity, or shown by credible sources to have, and effectively implement, requirements consistent with the revised FATF Recommendations, as potentially lower-risk factors. Annex III lists the opposite indicators for third countries, and Article 34(1) requires enhanced due diligence in the cases referred to in Articles 29, 30 and 31, which cover third countries identified by the Commission. The geography factor therefore needs a current check against those identifications as well as against the other Annex III factors.

Related Articles

• AMLA Final RTS: CDD Data, Linked Transactions and Group-Wide Rules: the data fields, linked-transaction rules and group-wide controls in AMLA’s three final draft RTS of 1 October 2026.
• The EU AML Package: The Countdown to 10 July 2027: how the AMLR, AMLD6 and AMLA fit together ahead of the 10 July 2027 application date.
• BaFin AMLA Guidelines: Overview Table Replaces Adoption Circulars: how BaFin now records which AMLA and ESA guidelines it applies.
• AMLA Central Contact Point Survey: The 15 September Deadline for PSPs: AMLA’s survey of payment and e-money institutions feeding a successor RTS.
• AMLA Home-Host Supervisory Cooperation: Final RTS and Group Data Flows: what supervisors of cross-border groups share under AMLA’s final home-host RTS.

Key Takeaways

• Pick the nominated representative before applying: the call expects practical expertise, seniority and authority to speak for the organisation, in English, in person in Frankfurt.
• Frame every scenario around one Article 33(1) reduction, points (a) to (d); new measure types belonged to the Article 28 RTS, which added no horizontal ones.
• Pooled-account SDD has left the RTS: AMLA’s final report says it is better addressed through guidelines and names no instrument or date, so firms relying on it should not plan around the consultation-draft RTS text.
• Schedule low-risk customer refreshes inside the five-year ceiling in Article 26(2)(b) AMLR before 10 July 2027.
• Build Article 33(4) re-testing and the Article 33(5) exit triggers into monitoring, with targeted financial sanctions screening left at full strength.
• Treat EBA/GL/2021/02 as the working reference for credit and financial institutions while it remains relevant, until AMLA’s own guidelines apply at the end of their transition period.
• Strip customer-level data, suspicious transaction information and privileged material from the expression of interest; use aggregates for prevalence.

Sources and References

• AMLA, AMLA invites stakeholders to sectoral roundtables on simplified customer due diligence (news, 2 October 2026): https://www.amla.europa.eu/amla-invites-stakeholders-sectoral-roundtables-simplified-customer-due-diligence_en
• AMLA, Call for expressions of interest: participation in AMLA sectoral roundtables on simplified customer due diligence measures (2 October 2026): https://www.amla.europa.eu/document/download/371150ff-9e59-406c-88ef-ecb85ebae06d_en?filename=EOI%20-%20SDD%20roundtables.pdf
• AMLA, News announcement PDF on the SDD roundtables (2 October 2026): https://www.amla.europa.eu/document/download/af293466-527f-4cfd-950b-d165a08a2678_en?filename=News%20Announcement%20-%20SDD%20GL.pdf
• AMLA, EU Survey form for expressions of interest: https://ec.europa.eu/eusurvey/runner/13f29e73-3400-7eb1-9e1a-0ddce20da628
• AMLA, Final Report: Draft Regulatory Technical Standards under Article 28(1) of Regulation (EU) 2024/1624 (30 September 2026): https://www.amla.europa.eu/document/download/e15ab2e5-4074-4de8-bb9d-613dd8b7fdd1_en?filename=Final%20Report%20-%20draft%20RTS%2028%281%29%20AMLR.pdf
• AMLA, Press release: AMLA finalises key standards for the private sector (1 October 2026): https://www.amla.europa.eu/press-release-amla-finalises-key-standards-private-sector_en
• AMLA, Public consultations: https://www.amla.europa.eu/policy/public-consultations_en
• AMLA, Consultation on the draft Guidelines on ongoing monitoring of a business relationship (Article 26(5) AMLR): https://www.amla.europa.eu/policy/public-consultations/consultation-draft-guidelines-ongoing-monitoring-business-relationship_en
• AMLA, Regulatory instruments (including EBA guidelines that remain applicable): https://www.amla.europa.eu/policy/regulatory-instruments_en
• Regulation (EU) 2024/1624 (AMLR), Articles 19, 20, 22, 26, 28, 33, 34, 42, 90, recital 78 and Annexes II and III, EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1624
• Regulation (EU) 2024/1620 (AMLAR), Article 54, EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1620
• Directive (EU) 2024/1640 (AMLD6), Article 77, EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L1640
• Directive (EU) 2015/849, Articles 15 to 17, EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015L0849
• EBA, Press release: EBA publishes final revised Guidelines on money laundering and terrorist financing risk factors (1 March 2021): https://www.eba.europa.eu/publications-and-media/press-releases/eba-publishes-final-revised-guidelines-money-laundering-and
• EBA, Guidelines on ML/TF risk factors (EBA/GL/2024/01, amending EBA/GL/2021/02): https://www.eba.europa.eu/legacy/regulation-and-policy/regulatory-activities/anti-money-laundering-and-countering-financing-1

Deciding on the AMLA SDD roundtables before the 18 October cut-off

The decision is small and the window is short: submit an expression of interest through the EU Survey form, or rely on the later public consultation. For applicants, the next fixed date is 30 October 2026, the date by which AMLA says it will inform every applicant of the outcome. The artefact to have ready by then is the scenario set itself: each recurring low-risk situation, its prevalence in aggregate, the Article 33(1) point it relies on and the Article 33(5) triggers that take it out of SDD.

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.