Regulatory Alerts2026-05-13
Enterprises Need Not Expect a Separate AMLA Reporting Request
The Netherlands Authority for the Financial Markets (AFM) has announced that financial enterprises under its supervision do not need to submit a separate AMLA eligibility reporting template, as the required data will instead be collected through existing AFM questionnaires. This integrated approach aligns with the European Anti-Money Laundering Authority’s (AMLA) new eligibility criteria while minimizing administrative burdens for regulated institutions. Firms, particularly investment funds and UCITS managers, are urged to complete the upcoming June or July questionnaire to ensure a smooth transition to direct AMLA supervision.
News
13/05/26
The European Anti-Money Laundering Authority (AMLA) published the definitive eligibility reporting package on 12 May in a press release and announced that it will request additional data through national supervisors. Financial enterprises under Dutch supervision do not need to submit separate reporting according to the AMLA template. The questions have been integrated into existing questionnaires of the Netherlands Authority for the Financial Markets (AFM).
In short
• AFM opts for integration into existing questionnaires. • AFM aims to implement European requirements with minimal administrative burden
AFM opts for integration into existing questionnaires
AMLA has published a reporting package containing criteria to determine which enterprises may fall under AMLA’s direct supervision. The additional data requested by AMLA is used to determine which enterprises are ‘eligible’, meaning: they may fall under AMLA’s direct supervision. In the Netherlands, these so-called eligibility criteria are not requested via a separate AMLA template. The relevant questions have already been incorporated into the standard questionnaires we send to enterprises under our supervision. Only for the target group of (managers of) investment funds and UCITS will they receive questions on this matter from the AFM in June or July. Answering these questions is important as it contributes to a smooth transition to future AMLA supervision.
AFM aims to implement European requirements with minimal administrative burden
With this approach, we aim to implement the Anti-Money Laundering package with minimal administrative burden for institutions, while simultaneously aligning with European requirements. Enterprises can inform themselves about AMLA’s eligibility reporting package and the associated webinar on 10 June referenced in AMLA’s press release, but should not expect any additional requests from the AFM conforming to the AMLA template.
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Advisers, intermediaries & representatives
Investment funds
Investment firms
Crypto service providers
Preventing money laundering and terrorist financing - compliance with the Sanctions Act
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