EBF feedback on AMLA Draft Regulatory Technical Standard on Customer Due Diligence under Article 28(1) AMLR

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Brussels, 7 May 2026 – The European Banking Federation (EBF) submitted on 7 May its feedback on AMLA Draft Regulatory Technical Standard (RTS) on Customer Due Diligence Article 28(1) – Regulation (EU) 2024/1624)

The EBF’s key outstanding concerns relate to ensuring that the RTS remain proportionate, risk-based and operationally workable.

In particular, the sector is seeking greater flexibility in customer identification and verification requirements, including avoiding unnecessary re-verification where a customer’s identity has already been properly established, applying a pragmatic approach to data points such as place of birth and multiple nationalities, and allowing the continued use of existing remote identification solutions pending the full deployment of eIDAS 2.0 tools.

The EBF is also calling for clearer and narrower definitions regarding Senior Managing Officials and persons acting on behalf of customers, so that obligations focus on individuals with legal authority to bind the company and remain aligned with Level 1 requirements.

In addition, the EBF is advocating for a genuinely risk-based approach to ownership and control structures, avoiding automatic classifications of complexity based solely on the number of ownership layers and preventing disproportionate CDD obligations in relation to end-investors and underlying clients.

For low-risk situations, the sector is requesting confirmation that perpetual KYC approaches are sufficient without mandatory periodic customer outreach or proactive data updates where no risk indicators exist.

Finally, the EBF stresses the need for a phased implementation of the RTS.

For more information:

Roger Kaiser, Head of Tax and Compliance – r.kaiser@ebf.eu

About the EBF:

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.