White Paper - AMLR and eIDAS 2.0

On 10 July 2027, Regulation (EU) 2024/1624 becomes directly applicable throughout the European Union. In other words, this is the new Regulation on the Prevention of Money Laundering (AMLR). One distinction should be emphasised at the outset: the Regulation came into force in 2024, but it will only apply from that date.

For the first time, therefore, the rules for combating money laundering are no longer subject to fragmented transposition by each Member State. Instead, they come into force uniformly throughout the Union.

In this context, Article 22(6)(b) of the AMLR codifies the accepted methods for distance identity verification. On the one hand, it recognises the means of electronic identification in accordance with Regulation (EU) No 910/2014 at guarantee levels «substantial» or «high». It also recognises the relevant qualified trust services. These include, inter alia, Qualified Electronic Signatures (QES) and Attribute Qualified Electronic Certificates (QEAA).

In parallel, Article 5f of eIDAS 2.0 also imposes an additional obligation on financial institutions: the acceptance of EUDI Wallet at the user's request. In particular, the period shall be 36 months from the entry into force of the respective implementing acts, i.e. until 24 December 2027.

Therefore, in this white paper, we examine the impact of these amendments. In addition, we explain what they represent for due diligence concerning customers (CDD). Finally, we present a practical roadmap for preparation aimed at compliance, operations and technology managers.