AMLR LEI Rules in Ireland: Customer Checks From 2027

The AMLR LEI rule will require banks and other obliged entities in Ireland to obtain a legal entity customer’s identifier where available from 10 July 2027; it does not require the customer to obtain one. The rule appears in Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR). Related customer due diligence standards submitted by AMLA remain in draft and are not yet binding.

What this means in Ireland

Ireland’s AML law is the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. The Central Bank of Ireland supervises AML/CFT compliance of credit and financial institutions. From 10 July 2027, the AMLR will apply directly in Ireland: its Article 22 identification list for legal entities includes the tax identification number and the Legal Entity Identifier (LEI) where available. The AMLR does not need national transposition for its rules.

Consider an LTD or DAC opening a business account with a bank in Ireland. If the company has an LEI, it can have that identifier ready when the bank requests customer information under the applicable rules. If it has no LEI, Article 22’s wording does not require it to obtain one. The same distinction matters when an LTD or DAC is reviewed in its bank’s periodic KYC update: an available identifier is information to provide, not a new obligation to register for one under the AMLR.

Ireland’s beneficial ownership register is the Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (RBO). Search access on the RBO register is only available to designated persons. The RBO and the AMLR’s LEI information requirement concern different information; the existence of the register does not change Article 22’s words, ‘where available’. Where a particular customer or arrangement raises a question about which requirements apply, check with the regulator or an adviser.

Key points on AMLR LEI checks

• The AMLR was published in the Official Journal on 19 June 2024. It is binding in its entirety, but most obliged entities will apply its customer-identification requirements from 10 July 2027.
• Article 22 calls for an LEI for a legal entity customer where available. It does not direct customers without an LEI to obtain one.
• AMLA’s final 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 remain subject to review and possible amendment.
• An Irish company with an existing LEI can check its code and keep it ready for requests from an obliged entity.

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 information obliged entities must obtain to identify a legal entity customer: its legal form and name; the address of its registered or official office, any different principal place of business and country of creation; and the names of its legal representatives. It also lists 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.

Article 22 also addresses customers other than companies. For a trustee of an express trust or someone in an equivalent position in a similar legal arrangement, 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. The appropriate category depends on the customer.

The list of obliged entities in Article 3 includes credit institutions, financial institutions, auditors, external accountants, tax advisers, trust or company service providers and estate agents. It also includes notaries, lawyers and other independent legal professionals for certain transactions. An LEI request connected with customer identification may therefore come from an organisation other than a bank.

What AMLA’s draft standards 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 standards were submitted to the Commission. Submission does not make them binding.

In low-risk situations, draft Article 18 lists minimum information for a legal entity, including its legal form, legal name, any different trade name and registered or official office address. It also includes, where available, a registration number or tax identification number, or the LEI. Draft Annex I places the LEI, where available, among the legal entity attributes mapped to electronic identification means and qualified trust services.

For business relationships established before the standards enter 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). That AMLR provision limits the time 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 entry into force, once adopted and published in the Official Journal; that interval is a proposal, not an application date already fixed for binding standards.

How payment-message LEI rules differ

Regulation (EU) 2023/1113, Article 4(1)(d) and 4(2)(c), has applied since 30 December 2024. It concerns information accompanying transfers of funds, rather than the AMLR’s list of customer-identification information.

Under the conditions stated in that regulation, 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 where there is no LEI. The relevant field must exist in the payment message format, and the payer must provide the identifier to its payment service provider.

Steps for an Irish entity before 10 July 2027

1. Check whether your entity has an LEI. Keep the existing code accessible to staff handling bank onboarding or customer-information requests.
2. Review an existing identifier. If its details need updating, consider renewing the LEI so the available record reflects the entity’s current details.
3. Distinguish an available LEI from a requirement to obtain one. The AMLR does not impose the latter. If an entity wants an identifier it can supply during these checks, it can consider applying for an LEI.
4. Check case-specific questions. Ask the regulator or an adviser if the treatment of a trust, another organisation or a particular transaction is unclear.

Timeline: applicable rules and draft standards

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, including Article 22’s LEI provision.	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 LEI regulation updates in Ireland, distinguish the AMLR’s application date from the draft standards’ proposed timetable. For now, check whether your entity already has an LEI and keep its code available if it does.