| No | Empowerments | Basic act (name + number) | Legal basis | Shall/May | Currently scheduled adoption date by the Commission |
|---|---|---|---|---|---|
| 46 | ITS on the format for reporting of information by AMLA to EPPO | AMLA Regulation - (EU) 2024/1620 | Art. 41(2) | Shall | 2026 Q4 |
| 47 | RTS on general conditions for the functioning of AML/CFT supervisory colleges in the non-financial sector | AMLD - (EU) 2024/1640 | Art. 50(13) | Shall | 2027 Q1 |
| 48 | RTS on general conditions for the functioning of AML/CFT supervisory colleges in the financial sector | AMLD - (EU) 2024/1640 | Art. 49(14) | Shall | 2027 Q1 |
| 49 | ITS on the template to be used for the conclusion of cooperation agreements with supervisors in third countries | AMLD - (EU) 2024/1640 | Art. 51(4) | Shall | 2029 Q3 |
| 81 | DA on common additional categories of prominent public functions | AMLR - (EU) 2024/1624 | Art. 43(3) | Shall | N/A |
| 82 | DA on categories of corporate entities associated with higher risks and associated lower Beneficial Ownership thresholds | AMLR - (EU) 2024/1624 | Art. 52(2) | Shall | N/A |
| 113 | IA on the methodology for the collection of statistics | AMLD - (EU) 2024/1640 | Art. 9(5) | May | N/A |
De-prioritisation of Level 2 acts in financial services legislation
On October 1st, 2025, the European Commission’s Directorate-General for Financial Stability (DG FISMA) announced a wide-ranging simplification initiative for EU financial services law. Out of 430 empowerments for secondary legislation (“Level 2 acts”), 115 were classified as non-essential and will not be adopted before October 1st, 2027. The measure aims to reduce legislative congestion and focus resources on the implementation of key priorities.
While the decision affects multiple policy areas, it has particular relevance for the EU Anti-Money-Laundering and Counter-Terrorist-Financing (AML/CFT) package, notably the following three instruments:
- AMLAR – Regulation (EU) 2024/1620 – establishing the EU Anti-Money-Laundering Authority (AMLA),
- AMLR – Regulation (EU) 2024/1624 – the directly applicable AML Regulation, and
- 6AMLD – Directive (EU) 2024/1640 – the accompanying directive on national AML frameworks.
AMLAR – Regulation (EU) 2024/1620
Item 46 – Implementing Technical Standards (ITS) on the format for reporting by AMLA to the EPPO (Art. 41 (2))
Originally scheduled for Q4 2026, this ITS was intended to define a uniform template for AMLA’s information reporting to the European Public Prosecutor’s Office (EPPO). Its de-prioritisation means AMLA and national Financial Intelligence Units will continue relying on interim formats and bilateral arrangements. Institutions engaged in cross-authority cooperation should therefore maintain adaptable reporting schemas that can later align with the final ITS once adopted.
6AMLD – Directive (EU) 2024/1640
Three of the directive’s planned regulatory and implementing acts are affected:
Item 47 – RTS on AML/CFT supervisory colleges in the non-financial sector (Art. 50 (13))
Item 48 – RTS on AML/CFT supervisory colleges in the financial sector (Art. 49 (14))
Item 49 – ITS on cooperation templates with third-country supervisors (Art. 51 (4))
These acts, initially foreseen between 2027 Q1 and 2029 Q3, are placed on hold. Until formal RTS and ITS are issued, supervisory colleges for both financial and non-financial entities will operate under the Level 1 provisions of the AMLD, guided by existing EBA and ESAs’ cooperation guidelines. This effectively preserves current practices, allowing member states to structure their supervisory cooperation flexibly.
A fourth item, Item 113 – Implementing Act on the methodology for the collection of statistics (Art. 9 (5)), was optional (“may”) even before the announcement and now lacks any indicative timeline. Statistical data collection and reporting will therefore continue under national or ESA-defined methodologies until further harmonisation.
AMLR – Regulation (EU) 2024/1624
Two planned Delegated Acts (DA) under the directly applicable AML Regulation are also deprioritised:
Item 81 – DA on additional categories of prominent public functions (Art. 43 (3))
This measure would have expanded the EU-wide list of politically exposed persons (PEPs) beyond the core categories already defined in the regulation. Its postponement means obliged entities must continue using the AMLR’s default PEP list without anticipating new roles or functions. Screening systems should remain configurable to absorb any later updates once the DA is eventually adopted.
Item 82 – DA on high-risk corporate categories and lower beneficial-ownership thresholds (Art. 52 (2))
Originally intended to identify specific corporate structures warranting reduced ownership thresholds (below 25 %) for beneficial-owner disclosure, this delegated act will also be delayed. Financial institutions should therefore maintain the general 25 % standard but treat higher-risk structures (e.g. trusts, foundations, complex holding chains) through their own risk-based enhanced due-diligence policies.
Implications and Outlook
The two-step approach announced by the Commission provides:
- No adoption of the listed non-essential acts before 1 October 2027; and
- Potential amendment or repeal of the underlying empowerments during the next review of the relevant Level 1 acts.
For the AML community, this effectively freezes secondary rulemaking for several operational and technical aspects of the new AML framework. Compliance officers and policymakers should therefore:
- Work directly with the Level 1 texts of Regulations 1620 and 1624 and Directive 1640;
- Avoid premature reliance on unissued technical standards;
- Keep internal systems and policies modular, allowing later integration of final RTS, ITS, or DAs.
The Commission’s simplification drive marks a pragmatic pause in the roll-out of detailed secondary rules under the new EU AML regime. While this reduces immediate regulatory workload, it extends a period of legal uncertainty for technical implementation. Firms should anchor compliance on the core provisions of the AMLA Regulation, AML Regulation, and AML Directive, while monitoring the post-2027 agenda for the eventual reactivation or amendment of the deferred empowerments.
Sources: