A common EU form for reporting suspicions is out in draft, and it does not land on every firm the same way. If your FIU's platform generates your reports, the form changes and you fill it in. If your own systems generate them, you build the new requirements in yourself.
This is a consultation paper and it binds no one yet. AMLA published it on 2 July 2026, comments close on 20 September 2026 at 23:59 CEST, and a public hearing runs on 9 September 2026 from 10:00 to 12:00 CEST. AMLA will consider the feedback when preparing its submission to the European Commission by 30 November 2026. Article 69(1) of Regulation (EU) 2024/1624 already requires obliged entities to report, on their own initiative, any suspicion that funds or activities may be the proceeds of criminal activity or are related to terrorist financing or criminal activity, and to give the FIU, at its request, all necessary information including information on transaction records. Article 69(3) tells AMLA to specify the format.
Article 10 of the draft splits the build in two. FIUs are to implement the annexes into their national reporting systems within a number of years following the Commission's adoption of the reviewed annexes. Obliged entities come next, and only some of them: where not using FIUs' reporting platforms for generating their reports, obliged entities are to implement the requirements laid down in the annexes into their internal systems, within a number of years following the General Board decision on the review. Put plainly: if the FIU's platform generates your report, the platform is what gets rebuilt. If your own system generates it, building the annex requirements into it is your job.
Both periods are blank. The draft says "within [...] years" in each place, and AMLA says in the consultation that the exact timeframe is not determined yet, and that it is envisaged to provide five years, three for FIUs and two for obliged entities integrating the reporting schemes into their internal systems, with a possible overlap.
Filling the form in is not conditional on any of that. When reporting suspicions, obliged entities are to report the information requested in their corresponding template, composed of data points common to all obliged entities together with data points adapted to the activity performed. Annex I sets out nine: financial institutions and credit institutions; credit intermediaries for mortgage and consumer credits other than credit and financial institutions; crowdfunding service providers and intermediaries; notaries; real estate professions; auditors, external accountants, tax advisors, other legal professionals and trust or company service providers; persons trading in precious metals and stones, in high-value goods and in cultural goods; providers of gambling services; and football agents and professional football clubs.
Inside a template every data point carries a treatment, and that is the part to read twice. Mandatory points are provided systematically, and among them the technically required ones are those whose absence breaks the FIU's validation rules and so prevents the report being submitted at all. Mandatory if available means provided where the information is available to the obliged entity at the time of reporting. Optional means provided voluntarily where the entity considers the point relevant to better substantiate the suspicion. Dependent means required only when a specific parent data point or circumstance is present. FIU-required means a point an FIU may require only if it is required under national legislation or specific national circumstances.
Transaction records are a narrower duty. Article 4 is addressed to credit institutions and financial institutions: on an FIU's request they are to use the template corresponding to the type of activity they are reporting and to provide all requested information that is in their possession. Annex II carries four, for banking activities, money remittance activities, crypto-asset service providers and correspondent services. Article 4 names credit institutions and financial institutions and no other addressee.
So the question to settle before the form arrives is not what it asks. It is whose system generates your reports. The draft already says who has to build it. It has not said by when, that number is still an empty bracket, and 20 September is the last day anyone gets to argue about either.
Not legal advice. Verify against the primary source before acting.
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