Article 28 Transitional provisions


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 28 of the RTS on customer due diligence say?

This is a transitional provision that addresses how obliged entities should handle existing customer relationships that were established before this Regulation came into force.

Rather than requiring an immediate overhaul of all existing customer records, it provides a measured approach by linking the timeline for compliance to Article 26(2) of Regulation (EU) 2024/1624, and requiring that updates be carried out on a risk-sensitive basis.

Important points:

  • Bring all existing customer documents, data, and information into line with the requirements of this Regulation and Regulation (EU) 2024/1624.
  • This obligation applies to business relationships established before the Regulation's entry into force.
  • The timeframe for compliance is governed by Article 26(2) of Regulation (EU) 2024/1624, and must be approached on a risk-sensitive basis.

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

  1. In the case of existing business relationships established before the date of entry into force of this Regulation, the documents, data and information relating to those customers shall be brought in line with the requirements of this Regulation and Regulation (EU) 2024/1624 on a risk-sensitive basis within the periods set out in Article 26(2) of Regulation (EU) 2024/1624.

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