Article 1 Proportionality and risk-based approach


This is a draft act

This text has been parsed from the AMLA final report draft as published on 30 September 2026. While we run a suite of validations, the automated parsing can result in errors. Also, before it is finally adopted by the Commission, its wording, numbering and references may change, and entire articles might be removed or added.

Earlier drafts: AMLA consultation paper draft (9 February 2026)

Summary What does Article 1 of the RTS on customer due diligence say?

This is the foundational article of the Regulation, establishing the overarching principle that governs how all subsequent rules must be applied.

It sets out that the risk-based approach is the lens through which obliged entities must operate, meaning that the information gathered and measures taken must be calibrated to the specific type and level of risk identified.

It also flags that this includes the possibility of applying simplified due diligence where risk is low, signalling that the Regulation is not a one-size-fits-all framework.

Important points:

  • Apply the risk-based approach as the governing principle across all customer due diligence measures under this Regulation.
  • The information obtained and measures applied must be proportionate to the type and level of risk identified.
  • Simplified due diligence measures are explicitly recognised as a valid tool in low-risk situations.

Springlex's summary of the article is a reading aid, not a substitute for the legal text.

  1. This Commission Delegated Regulation (‘Regulation’) shall be applied in line with the risk-based approach. The extent and the nature of the information to be obtained and the measures to be applied by obliged entities shall be proportionate to the type and level of risk identified and shall enable obliged entities to manage and mitigate that risk appropriately, including through the application of simplified due diligence measures in situations of low risk.

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We offer professional services concerning information security governance, risk and compliance.

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