AMLR LEI Rules for Customer Checks in Luxembourg

The AMLR LEI rule will affect customer checks in Luxembourg from 10 July 2027: banks and other obliged entities will obtain a legal entity customer’s Legal Entity Identifier where available. It does not require a company without an LEI to obtain one. AMLA has submitted supporting customer due diligence standards, but they remain a draft as of 17 October 2026.

What this means in Luxembourg

Luxembourg’s existing AML law is the law of 12 November 2004 on the fight against money laundering and terrorist financing, available in consolidated form from the CSSF. The EU Anti-Money Laundering Regulation, Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR), will apply directly in Luxembourg from 10 July 2027. Its rules do not require national transposition.

For a Luxembourg SARL or SA opening a business account with a bank, Article 22’s identification list will be relevant when the bank checks the legal entity customer. That list includes the tax identification number and the LEI where available. The same wording matters for a SARL or SA reviewed in its bank’s periodic KYC update: an existing LEI can be supplied, but the AMLR does not tell a customer without one to obtain it.

Luxembourg also has the Registre des bénéficiaires effectifs (RBE), its beneficial ownership register, run by Luxembourg Business Registers (LBR). The RBE and an LEI are different reference points for a company’s information. The Article 22 question here is whether an LEI is available to give the obliged entity; it should not be confused with identifying the beneficial ownership register.

If the treatment of a particular entity or customer check is uncertain, confirm the position with the relevant regulator or an adviser. Neither the existence of Luxembourg’s 2004 law nor the RBE changes Article 22’s where available wording.

AMLR LEI checks: key points

• The AMLR was published in the Official Journal on 19 June 2024. It is binding in its entirety, but its general application date is 10 July 2027.
• Under Article 22(1), point (b), obliged entities will 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 submission of the draft to the Commission on 1 October 2026; the standards are not yet binding.
• A company with an LEI should know its code and be ready to provide it when customer information is requested.

Which customers and obliged entities are covered?

Article 2(1), point (27), defines a Legal Entity Identifier as a unique alphanumeric reference code based on ISO 17442 and assigned to a legal entity. Article 22(1), point (b), sets out what an obliged entity must obtain to identify a legal entity customer: its legal form and name, registered or official office address, any different principal place of business, country of creation and names of its legal representatives. It also includes the registration number, tax identification number and LEI where available, plus the names and nominee status of persons holding shares or directorships in nominee form.

That qualification is the limit of the LEI requirement in the identification list. The obliged entity obtains an LEI if one is available; Article 22 does not impose a duty on the customer to apply for one. Whether other identification details are needed remains a separate question under the provision.

Article 22 also addresses trustees of express trusts and people in equivalent positions in similar arrangements: point (c) includes the tax identification number and LEI where available. For other organisations with legal capacity under national law, point (d) includes the LEI where applicable. Which category fits 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. An LEI request under these customer checks need not come only from a bank.

What AMLA’s submitted draft would 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. AMLA’s 1 October 2026 press release says the final draft was submitted to the European Commission. Commission review and possible amendment remain ahead; these draft provisions are not binding rules.

Draft Article 18 deals with 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. Draft Annex I also includes the LEI where available in its mapping of legal-entity data points to attributes for electronic identification means and qualified trust services.

For business relationships predating the standards’ entry into force, draft Article 28 proposes aligning customer documents, data and information on a risk-sensitive basis within the periods in AMLR Article 26(2). Under that AMLR provision, the interval between customer-information updates must not exceed one year for higher-risk customers and five years for other customers.

AMLA proposes that the standards apply six months after entering into force, once adopted and published in the Official Journal. That is a proposal about timing, not an announcement that the submitted text has been adopted.

Keep payment-message LEI rules separate

Another EU provision already uses LEIs for transfers of funds. Regulation (EU) 2023/1113, Article 4(1)(d) and 4(2)(c), applies from 30 December 2024 and concerns information accompanying payment messages, not the AMLR’s customer-identification list.

Under the conditions in that provision, 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 depends on the relevant field existing in the payment message format and the payer providing the identifier to its payment service provider. It should not be read as changing Article 22’s where available condition for customer checks.

What to do before 10 July 2027

1. Find any existing LEI. If your entity has one, keep its code accessible for a bank or another obliged entity conducting identification checks.
2. Review its details. If an existing identifier needs updating, consider renewing the LEI so its recorded details reflect the company.
3. Separate choice from obligation. The AMLR does not require an entity without an LEI to obtain one. If your entity wants a standard, verifiable identifier to provide during checks, it can consider applying for an LEI.
4. Check uncertain cases. Ask your regulator or adviser where an entity’s category or the requirements of a particular transaction depend on its facts.

Dates and status at 17 October 2026

Date	Development	Status
30 December 2024	Regulation (EU) 2023/1113 applies to information accompanying transfers of funds.	In force
30 September 2026	AMLA’s 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 in Luxembourg, 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.

For a Luxembourg customer check, first establish whether your entity already has an LEI and have the code ready if it does. Track subsequent developments through our LEI regulation updates.