What is the situation
AFM said on 13 May 2026 that financial undertakings under Dutch AFM supervision should not expect a separate AMLA eligibility template. AMLA, the EU Anti-Money Laundering Authority, published its final eligibility reporting package on 12 May. AFM has placed the relevant questions inside existing questionnaires. Managers of alternative investment funds and UCITS will still receive extra AFM questions in June or July 2026. The wider timing matters: the first AMLA selection process must start by 1 July 2027, and the new EU AML/CFT framework applies from 10 July 2027.
Analysis
This is administrative consolidation, not deregulation. A missing separate template can save time, but ordinary AFM questionnaires now carry more weight. For small firms, the practical exposure is inconsistency: answers that do not match client files, ownership checks, risk ratings, sanctions screening, escalation notes or management decisions. Proportionality remains available under EU rules, but it must be explainable. A small business does not need bank-sized machinery. It does need records that show why its controls fit its clients, products, jurisdictions and risk.
Prepare for the upcoming AML/CFT framework by ensuring your compliance records are robust and aligned, start your file clean-up today!
Impact
H1
Treat the next AFM questionnaire as a control file, not a form. Identify who owns the answers and whether the data comes from current files rather than memory, estimates or inbox searches.
H2
Budget time for file clean-up, staff handover and sanctions-screening discipline before the 2027 transition compresses calendars. For fund and UCITS managers, prepare for the June or July extra questions.
H3
The structural shift is toward European risk classification through normal supervisory data. Pricing, staffing and client acceptance need to reflect that compliance evidence is part of the service cost.
Daily operational takeaway
Select five higher-risk client files and check whether risk rating, beneficial-owner data, politically exposed person handling, sanctions screening and approval notes tell the same story.
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by the author before publication. Any translated versions are AI-generated from the original English text.
