Getting with the programme

On 4 February AMLA published its first Single Programming Document (SPD). First announced in AMLA’s 2025 work programme, the SPD sets out the authority’s strategic priorities and work plans for 2026-2028, presenting how AMLA will deliver its three core missions of completing the single AML rulebook, advancing supervisory convergence and strengthening cooperation among Financial Intelligence Units (FIUs).

The SPD lays out AMLA’s five strategic objectives:

• Convergence, Consistency and Proportionality
• Cooperation and Inclusiveness
• Technology and Innovation
• Credibility and Accountability
• Global Leadership

It then presents AMLA’s activity over the coming years in five interlinked areas:

1. delivering on core regulatory mandates
2. advancing direct supervision
3. operationalizing the FIU framework
4. laying the foundations for indirect supervision and oversight, and
5. building AMLA’s risk frameworks

Under the AML reform package legislation (AML Regulation, 6^th AML Directive and AMLA Regulation), AMLA is mandated to produce around 40 different regulatory or implementing technical standards (RTS / ITS) and guidelines to complete the EU single AML rulebook.1

In December 2025, AMLA reviewed two RTS proposals from EBA — on assessing the risk of obliged entities, and on the methodology for selecting entities for direct AMLA supervision — following consultation by the European Banking Authority earlier in the year and agreed on the proposals without opening a new consultation. It also consulted on one ITS, on cooperation among AML supervisors.

Rulemaking will be a major area of focus for 2026. The SPD includes plans for consultation on multiple regulatory instruments during the course of the year:

This timetable is clearly highly ambitious, requiring AMLA to produce multiple texts simultaneously and leaving only short periods for AMLA to take account of stakeholder feedback on consultation drafts. This timetable is likely intended to give industry the maximum time to implement the final rules before the single AML rulebook takes effect in July 2027. Nonetheless, it is notable that the SPD timetable implies that at least 13 rules will not be finalised until after their statutory deadlines.² AMLA has not disclosed if it (or national authorities) will offer any supervisory forbearance to firms that are not yet compliant by July 2027. If delays in rulemaking make timely compliance impossible, however, supervisors may conclude they have little option but to show some flexibility.

As of April 2026, two AMLA public consultation procedures have already been completed, i.e. the consultation on the draft ITS under Article 15(3) of Directive (EU) 2024/1620, which ended in January 2026, and the consultation on the draft RTS on pecuniary sanctions, administrative measures and periodic penalty payments under Article 53(10) of Directive (EU) 2024/1640, closed at the beginning of March 2026. AMLA is currently reviewing industry comments and final drafts are expected to be published later on in the course of 2026.

On the FIU side, AMLA will fully operationalise its support and coordination framework. This will involve developing a robust framework for information sharing, including an enhanced FIU.net platform; finalising common standards for reporting suspicions; and enabling joint analyses. One priority area for analysis will be crypto-assets and other novel payment channels, which AMLA previously highlighted as posing particularly high money laundering and terrorist financing risks. Underpinning this collective effort, AMLA will set up mechanisms for joint training and sharing of expertise as well as mediation between FIUs.

Risk analysis is central to effectively tackling illicit finance. The last major area of activity identified in the SPD is therefore the development of AMLA’s risk framework. This will be built on AMLA’s data analysis systems and will allow for continuous monitoring and evaluation of money laundering and terrorism financing risks to the EU. In line with AMLA Chair Bruna Szego’s previous comments about bringing together the insights from both supervisors and FIUs, the risk framework aggregate risk data across areas of AMLA’s work. The goal is to reach a common understanding among EU authorities and obliged entities of the key risks.

2026 will be a decisive year for how the new EU AML regime will operate in practice. AMLA’s activities this year will both determine much of the detail of the new AML rulebook and shape how firms will be supervised, whether directly or indirectly by AMLA. Firms should closely monitor the evolution of AMLA policy and engage with the authority to shar their practical experience of what rules and controls are most practical and effective. In particular, firms should prepare for the multiple consultations on draft rules that AMLA will initiate this year and be ready to make their voices heard. The KPMG AMLA Office will continue to monitor and provide insights on the development of AMLA policy and practice, to help firms get ‘AMLA ready’.