Article 19 Identification and verification of the beneficial owner or senior managing officials in situations of low risk


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 19 of the RTS on customer due diligence say?

This article sits within the simplified due diligence framework of the regulation, building directly on Article 18 which sets out the minimum identification requirements in low-risk situations.

Article 19 extends that framework by specifying which information sources obliged entities may use to identify and then separately verify the identity of a beneficial owner or senior managing official when the risk level is low.

The key principle here is flexibility: obliged entities are not locked into a single prescribed source but may choose from a defined list, provided that the source used for verification is different from the one used for identification.

Important points:

  • In low-risk situations, identify the beneficial owner or senior managing officials using one of four permitted sources: the central register, a business or company register, customer-provided information, or a reliable independent open source.
  • To verify identity in low-risk situations, use a different source from the one used for identification — noting that the central register is not available as a verification source.
  • The obligation to use separate sources for identification and verification applies to obliged entities.

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

    1. In situations of low risk, obliged entities may identify the beneficial owner or senior managing officials by consulting one of the following sources of information:

      1. the information contained in the central register;

      2. the information contained in a business or company register;

      3. any information provided by the customer, including confirmation that the information obliged entities may already hold or that is shared within the group is adequate, accurate and up to date;

      4. any publicly available information contained in a reliable independent open source.

    1. To verify the identity of the beneficial owner or senior managing officials in situations of low risk, the obliged entity may consult one of the sources of information listed in paragraph 1, points (b) to (d), that was not used for identification purposes.

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