AMLR LEI Rules: What Changes for EU Customer Checks

The AMLR LEI rule does not require a company to obtain a Legal Entity Identifier. From 10 July 2027, banks and other obliged entities across the EU will obtain a customer’s LEI where available as part of identification checks. AMLA’s recently submitted customer due diligence standards retain the LEI in their final draft, but those standards are not yet binding.

Key points: what changes for LEI checks

• The EU Anti-Money Laundering Regulation, Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR), applies from 10 July 2027 for most obliged entities.
• Article 22 tells obliged entities to obtain a legal entity customer’s LEI where available.
• AMLA’s final report on draft customer due diligence standards is dated 30 September 2026; AMLA announced on 1 October 2026 that the final draft had been submitted to the Commission. The draft may still change.
• For a company that already has an LEI, the practical step is to know its identifier and be ready to provide it during customer checks.

The AMLR was published in the Official Journal on 19 June 2024. It is binding in its entirety and directly applicable in EU Member States, without national transposition of its rules.

What AMLR Article 22 says about legal entities and LEIs

Article 22 sets out information that obliged entities must obtain to identify customers. Under Article 2(1), point (27), a Legal Entity Identifier is a unique alphanumeric reference code based on ISO 17442 and assigned to a legal entity. For a legal entity customer, Article 22(1), point (b), includes its legal form and name, registered or official office address, any different principal place of business, country of creation and names of legal representatives.

That provision also lists the registration number, tax identification number and LEI where available. It separately covers the names of nominee shareholders and directors, together with their nominee status. The wording matters: the obliged entity collects an available LEI, but Article 22 does not require a customer that lacks one to obtain it.

The scope is wider than companies. For trustees of express trusts or similar arrangements, Article 22(1), point (c), refers to the tax identification number and LEI where available. Point (d) addresses other organisations with legal capacity under national law and includes the LEI where applicable. Whether a particular customer falls within one of these categories depends on its circumstances.

Article 3’s obliged entities include credit institutions, financial institutions, auditors, external accountants and tax advisers, trust or company service providers, and estate agents. It also covers notaries, lawyers and other independent legal professionals for certain transactions. A request for an existing LEI may therefore arise in customer due diligence beyond bank onboarding.

What AMLA’s final draft customer due diligence standards add

The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) final report on draft regulatory technical standards under AMLR Article 28(1) is dated 30 September 2026. According to AMLA’s 1 October 2026 press release, the final draft standards have been submitted to the European Commission. They remain subject to review and possible amendment; they are not yet binding.

Draft Article 18 addresses low-risk situations. Its minimum information for a legal entity includes legal form, legal name, a different trade name where applicable, the registered or official office address and, where available, a registration number or tax identification number, or the LEI. The draft thus retains the LEI as a possible data point even in the low-risk information list.

Draft Annex I maps AMLR data points to attributes that electronic identification means and qualified trust services should carry. For legal entities, that mapping includes the LEI where available.

For business relationships already in place before the standards enter into force, draft Article 28 proposes bringing customer documents, data and information into line on a risk-sensitive basis within the periods in AMLR Article 26(2). That AMLR provision limits the period between customer-information updates to one year for higher-risk customers and five years for all other customers.

AMLA proposes that the standards apply six months after they enter into force, once adopted and published in the Official Journal. Neither that proposed interval nor submission of the final draft means the standards have been adopted.

How this relates to LEIs in payment messages

LEIs already appear in another EU rule, but for a different purpose. Regulation (EU) 2023/1113, Article 4(1)(d) and 4(2)(c), applies from 30 December 2024. It addresses information accompanying transfers of funds rather than the AMLR’s customer-identification list.

Under its stated conditions, the payer’s payment service provider must ensure a transfer carries the current LEI of the payer and payee, or an available equivalent official identifier if there is no LEI. This is subject to the relevant field existing in the payment message format and the payer providing the identifier to its payment service provider.

What companies should do before 10 July 2027

1. Check whether your entity already has an LEI. If it does, identify the code that can be supplied when an obliged entity requests customer information.
2. Check the status of an existing identifier. If it needs updating, consider renewing an LEI so that the data a bank or other obliged entity sees matches the company’s current details.
3. Separate requests from legal duties. If your entity has no LEI, the AMLR does not require it to obtain one. An entity that wants to give banks and other obliged entities a standard, verifiable identifier for these checks can consider applying for an LEI.
4. Ask about case-specific requirements. If the status of a trust, organisation or particular transaction is unclear, check with your regulator or adviser.

If the status check shows that your LEI is LAPSED, renew the existing registration rather than applying for a new LEI, as explained in our guide to lapsed LEI status and renewal.

Timeline: rules in force and standards still in draft

Date	Event	Status as of 17 October 2026
30 December 2024	Regulation (EU) 2023/1113 applies to information accompanying transfers of funds.	In force
30 September 2026	AMLA’s final report on the draft customer due diligence standards is dated.	Final draft, not binding
1 October 2026	AMLA announces submission of the final draft standards to the Commission.	Subject to review and possible amendment
10 July 2027	The AMLR applies, including Article 22’s collection of an LEI where available.	Future application date
10 July 2029	The AMLR applies to football agents and professional football clubs.	Future application date

LEIs also feature in two related EU rules: a payer’s bank can offer Verification of Payee checks using an LEI as an alternative to checking the payee’s name, while under DORA banks and insurers identify ICT suppliers in their register of information using a valid LEI or EUID, as explained in our guide to DORA LEI requirements for ICT suppliers.

The next step is to check whether your entity already has an LEI and, if it does, keep its code available for customer-identification requests. For further changes, follow our LEI regulation updates.