AMLR LEI Rules in Belgium: What Changes for KYC

The AMLR LEI rule will affect customer identification checks in Belgium from 10 July 2027: banks and other obliged entities will obtain a legal entity customer’s Legal Entity Identifier (LEI) where available. It does not require a company without an LEI to obtain one. AMLA has submitted supporting draft standards, but they are not yet binding.

What this means in Belgium

Belgium’s existing AML law is the law of 18 September 2017 on the prevention of money laundering and terrorist financing (loi du 18 septembre 2017 / wet van 18 september 2017), as identified in the National Bank of Belgium’s AML supervision information. The National Bank of Belgium (NBB/BNB) supervises AML compliance at the financial institutions under its supervision. The FSMA’s AML supervision information covers the entities it supervises.

The change relevant to LEI checks comes from Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR). From 10 July 2027, it will apply directly in Belgium; its rules do not need national transposition. For legal entity customers, Article 22’s identification list includes the tax identification number and the LEI where available. This is a requirement to collect an available identifier, not a requirement for a Belgian company to acquire one.

Belgium also has a separate beneficial ownership register: the UBO register, run by the FPS Finance (SPF Finances / FOD Financiën). The UBO register and the LEI serve different purposes in this explanation: the AMLR provision addresses information obtained when an obliged entity identifies a customer. For a BV / SRL opening a business account with a bank in Belgium, the immediate question will be whether it already has an LEI to provide during that check.

AMLR LEI checks: key points

• The AMLR was published in the Official Journal on 19 June 2024. It is binding in its entirety, but most obliged entities will apply it from 10 July 2027.
• Article 22 says obliged entities must obtain a legal entity customer’s LEI where available; it does not tell customers without one to obtain one.
• AMLA’s report on draft customer due diligence standards is dated 30 September 2026. AMLA announced their submission to the European Commission on 1 October 2026; they may still change.
• A company that already has an LEI should be able to identify it when a bank or another obliged entity requests customer information.

Which customers and obliged entities are covered?

Under AMLR 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. Article 22(1), point (b), sets out the minimum information an obliged entity obtains to identify a legal entity customer. It includes the entity’s legal form and name, its registered or official office address, any different principal place of business, its country of creation and the names of its legal representatives.

The same provision includes the registration number, tax identification number and LEI where available. It also covers the names of persons holding shares or directorships in nominee form and their status as nominee shareholders or directors. The qualification matters for a Belgian BV / SRL reviewed in its bank’s periodic KYC update: if it has an LEI, it can provide that identifier; the wording does not require it to obtain one if it has none.

Article 22(1), point (c), addresses trustees of express trusts and people in equivalent positions in similar arrangements, including the tax identification number and LEI where available. Point (d) covers other organisations with legal capacity under national law and includes an LEI where applicable. The appropriate category for a particular customer depends on its circumstances.

Article 3’s obliged entities include credit institutions, financial institutions, auditors, external accountants, tax advisers, trust or company service providers and estate agents. Notaries, lawyers and other independent legal professionals are included for certain transactions. LEI questions in customer due diligence can therefore arise outside a bank relationship; check a case-specific position with your regulator or adviser.

What remains in AMLA’s draft standards?

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. AMLA’s press release of 1 October 2026 says the final draft was submitted to the Commission. Submission does not make the standards binding: they remain subject to review and possible amendment.

For low-risk situations, draft Article 18 lists minimum information about a legal entity: legal form, legal name, a different trade name where applicable, registered or official office address and, where available, a registration number or tax identification number, or the LEI. Draft Annex I also includes the LEI where available in its mapping of AMLR data points to attributes for electronic identification means and qualified trust services.

Draft Article 28 deals with business relationships already in place before the standards enter into force. It proposes aligning customer documents, data and information on a risk-sensitive basis within the periods set by AMLR Article 26(2): no more than one year between updates 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. That proposed interval is not an application date for standards that are still in draft.

LEIs in payment messages are a separate rule

Regulation (EU) 2023/1113, Article 4(1)(d) and 4(2)(c), has applied from 30 December 2024. It concerns information accompanying transfers of funds, rather than the AMLR list used to identify a customer.

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

What to do before 10 July 2027

1. Establish whether your entity has an LEI. Keep the code available if a bank or another obliged entity asks for it during identification checks.
2. Review an existing identifier. If its information needs updating, consider renewing an LEI so the details available to an obliged entity reflect your company’s current information.
3. Distinguish an LEI request from a duty to obtain one. The AMLR does not impose that duty on a customer without an LEI. If your entity wants a standard, verifiable identifier for these checks, it can consider applying for an LEI.
4. Check uncertain cases. Ask your regulator or adviser if the treatment of an arrangement, organisation or transaction is unclear.

Timeline for Belgium

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 draft customer due diligence standards is dated.	Final draft, not binding
1 October 2026	AMLA announces submission of the final draft to the Commission.	Subject to review and possible amendment
10 July 2027	The AMLR applies directly in Belgium, including Article 22’s LEI wording.	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.

Further developments can be followed in the LEI regulation updates. For your next customer check, establish whether your entity already has an LEI and keep the code to hand if it does.