EU Anti-Money Laundering Regulation (AMLR) for Accountants: What Applies from 2027
What the EU Anti-Money Laundering Regulation changes for accountants, auditors and tax advisors from 10 July 2027, and how to prepare.
The European Union has replaced much of its anti-money laundering (AML) rulebook with a directly applicable regulation, and it affects accountants, auditors and tax advisors in every member state. The Anti-Money Laundering Regulation (AMLR) entered into force on 9 July 2024 and begins to apply on 10 July 2027. Unlike the directives it replaces, a regulation applies as written, without each country transposing it into its own law, so firms that work across borders will meet more consistent rules. This guide summarises what Accountancy Europe, the body representing European professional accountancy organisations, says the AMLR changes for practitioners, which technical standards are still to come, and how to prepare. It is a summary of secondary guidance, not the regulation itself, so read the text of the AMLR and your national supervisor's guidance before you act. It is general information, not legal advice.
Who is covered?
According to Accountancy Europe's December 2024 factsheet, accountants, auditors and tax advisors are "obliged entities" under the AMLR. The obligation sits with the firm, not with individual accountants working within it, and in-house accountants serving businesses outside the AMLR's scope are exempt. If you work for a firm outside the EU that serves EU clients, check whether your activity brings you within scope under national law.
This guide concerns the EU. UK firms follow the Money Laundering Regulations 2017, which the 2026 amendments updated. See our guide to the 2026 amendments to the UK Money Laundering Regulations.
Key changes for practitioners
Accountancy Europe's factsheet highlights these changes:
- Occasional transaction threshold. The threshold for customer due diligence (CDD) on occasional transactions falls from EUR 15,000 to EUR 10,000, and occasional cash transactions of EUR 3,000 or more require at least identification and verification.
- Beneficial ownership. The ownership threshold is 25 per cent of shares, voting rights or other interests, direct or indirect. Member states may go lower but not below 15 per cent. Accountancy Europe's April 2025 advice notes that the wording changes from "more than 25 per cent" to "25 per cent or more", so some client portfolios may need remediation.
- Discrepancy reporting. Discrepancies with central beneficial ownership registers must be reported within 14 calendar days of detection, although minor or typographical errors can instead be sent back to the customer for correction.
- Refreshing information. Customer information must be updated at least every year for higher-risk customers and every five years for others.
- Enhanced due diligence. This includes senior management approval and source of funds checks, politically exposed person (PEP) measures apply for at least 12 months after a PEP leaves office, and firms cannot rely on entities in high-risk third countries.
- Record retention. Records must be kept for five years after a relationship ends or a transaction is completed, and authorities can request an extension of up to five more years.
Our guide to ultimate beneficial ownership for accountants explains how to trace owners, which becomes more important as the threshold wording changes.
Governance and outsourcing
The factsheet says firms must appoint a compliance manager from the management body and a senior compliance officer, and must have an independent audit function, which may be an external expert where a firm lacks one. Six core tasks cannot be outsourced, including suspicious activity reporting, customer risk profile decisions and approval of the business-wide risk assessment, and the supervisor must be notified before outsourcing begins. Training extends to everyone involved in AML measures, including employees, agents and distributors.
Groups and networks may be caught by group-wide requirements. The parent of a group must ensure branches and subsidiaries follow group policies and must carry out a group-wide risk assessment. Accountancy Europe's April 2025 advice says structures that share ownership, management or compliance controls, including networks and partnerships, may fall within this.
Provisions specific to the profession
Accountancy Europe points to these:
- Legal position exemption. CDD, discrepancy reporting and suspicious activity reporting do not apply when determining a client's legal position or representing them in judicial proceedings. The exemption falls away if the professional is involved in, or aware of, money laundering or terrorist financing.
- Self-regulatory body reporting. Member states may let accountants, auditors and tax advisors report suspicions through a self-regulatory body, which must forward them promptly to the financial intelligence unit.
- Information sharing. Disclosure is permitted between professionals in the same network, structure or partnership that shares common ownership, management or compliance control.
- Company formation. CDD is triggered when they take part in creating a legal entity or setting up a legal arrangement, or handle a transfer of ownership.
The technical standards still to come
The new Authority for Anti-Money Laundering (AMLA) will fill in much of the detail. Accountancy Europe's factsheet says AMLA is to issue standards by 10 July 2026 covering the content of business-wide risk assessments, ongoing monitoring, risk variables and group policies, and further standards by 10 July 2027 on outsourcing, reliance, suspicious activity indicators, PEP close-associate criteria and internal controls. AMLA ran consultations on draft standards between 9 February and 8 May 2026, including on CDD, and a commentary by the law firm A&L Goodbody noted that AMLA chose not to set additional lower occasional transaction thresholds. As of early July 2026, press reports said AMLA was due to submit its final draft CDD standards to the European Commission by 10 July 2026. Check AMLA's website for the current status, because the detail matters for your procedures.
How to prepare
Accountancy Europe's advice for practitioners translates into a practical plan:
- Start early. Smaller practitioners in particular must review AML compliance for every new and existing client.
- Map gaps. Compare your policies and procedures with the new requirements.
- Plan governance. Identify who will be the compliance manager, the compliance officer and the independent audit function.
- Re-categorise clients. Identify companies and their owners now, particularly those near the 25 per cent line.
- Check data suppliers. Firms remain responsible for information obtained from external data providers.
- Go beyond paperwork. Use checklists with understanding and judgement, not just to show documents exist.
- Tell clients early about the new obligations.
See our CPD courses for AML training, and use our AML and KYC guides hub to compare national regimes.
Frequently asked questions
When does the AMLR apply?
It entered into force on 9 July 2024 and begins to apply on 10 July 2027, according to Accountancy Europe.
Are accountants covered?
Yes. Accountants, auditors and tax advisors are obliged entities, and the obligation falls on the firm.
What is the beneficial ownership threshold?
25 per cent of shares, voting rights or other interests, direct or indirect. Member states may go lower but not below 15 per cent.
Can compliance be outsourced?
Partly. Six core tasks, including suspicious activity reporting and approving the business-wide risk assessment, cannot be outsourced.
Does the AMLR apply in the UK?
No. The UK follows the Money Laundering Regulations 2017. Firms with EU operations should check how the AMLR applies to them.
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