AML / Financial Crime in European Union

Key dates

2026-07-24

EBA published the draft technical package for reporting framework 4.4 and opened the consultation

2026-08-24 Deadline

Deadline for stakeholders to submit comments and suggestions on the draft technical package 4.4 and new glossary

2026-09-30

EBA expects to publish the final technical package for reporting framework 4.4

2026-12-31

First reference date for amended Pillar 3 ESG, equity and shadow banking disclosures; technical amendments for resolution planning, MREL decisions, Pillar 3 disclosure templates; and AMLA eligibility templates

2027-03-31

First reference date for new IFRS 18-aligned FINREP templates and FRTB-related disclosure templates

2027-12-31

First reference date for Pillar 3 ESG, equity and shadow banking disclosures for SNCIs

Suggested considerations

• Compliance teams may wish to assess the draft 4.4 package against current reporting architecture, especially where FINREP, Pillar 3, FRTB, resolution planning, MREL, or AMLA templates rely on local mapping or vendor implementation.
• Firms may wish to review the new IFRS 18-aligned FINREP templates and identify any chart-of-accounts, data lineage, or consolidation changes needed ahead of the 2027-03-31 first reference date.
• Reporting teams may wish to map the updated Pillar 3 ESG, equity exposure, and shadow banking disclosures to the 2026-12-31 reporting cycle, and to 2027-12-31 for SNCIs.
• Institutions may wish to compare their DPM 1.0 to DPM 2.0 conversion controls against the new glossary conversion file and plan for taxonomy or validation rule changes in downstream reporting tools.
• Affected firms may wish to submit comments on the draft technical package and glossary by 2026-08-24 if they have implementation concerns, data gaps, or interpretation issues.
• Compliance functions may wish to monitor the expected September 2026 final publication for changes to validation rules, AML eligibility elements, and the AMLA risk assessment 2027 templates.

What changed

The draft technical package for release 4.4 includes validation rules, the Data Point Model, XBRL taxonomies, and a new conversion file between DPM 1.0 and the DPM 2.0 glossary. It introduces amendments to the ITS on Pillar 3 disclosures on ESG risks, equity exposures and shadow banking exposures, with first reference dates of 2026-12-31 and 2027-12-31 for SNCIs. It also adds new IFRS 18-aligned FINREP templates, with a first reference date of 2027-03-31, and integrates FRTB-related disclosure templates into the DPM, also with a first reference date of 2027-03-31.

Key dates

10 January 2025

- The FASTER Directive was published in the Official Journal of the EU, establishing the legal basis for ESMA’s market capitalisation mandate

June 2025

- ESMA published a consultation paper on the draft RTS methodology for calculating market capitalisation and the market capitalisation ratio

25 July 2025

- The consultation period for ESMA’s draft RTS methodology closed

October 2025

- ESMA was expected to finalise the RTS and submit them to the European Commission

16 January 2026

- The European Commission issued a final document referring to the FASTER framework and its threshold mechanics

Suggested considerations

• Compliance teams should map whether any serviced Member State may approach or exceed the 1.5% threshold over a rolling four-year period and flag jurisdictions that could trigger special withholding tax relief consequences.
• Tax operations teams should align withholding tax relief workflows with the ESMA-published ratios so that jurisdictional eligibility assessments use the current official figures.
• Data and controls teams should document the calculation source, methodology, and reconciliation process for any internal use of ESMA market capitalisation data.
• Investment firms and intermediaries should review client-facing tax-relief processes to ensure they can respond to changes in Member State status under FASTER.
• Market-data and regulatory-reporting teams should prepare for annual updates by building a recurring review process around each ESMA publication cycle.

What changed

• - ESMA has started publishing annual market capitalisation figures and market capitalisation ratios for each EU Member State under its FASTER Directive mandate.
• The published figures are based on a harmonised methodology developed by ESMA in technical standards, using transaction data reported under MiFIR.
• Market capitalisation is calculated from shares admitted to trading on a regulated market or multilateral trading facility, with aggregation at the level of the issuer’s legal address in the relevant...
• The market capitalisation ratio is calculated as the Member State’s market capitalisation divided by the total market capitalisation of all Member States on the same date, expressed as a percentage.
• Member States whose market size exceeds 1.5% of total EU market capitalisation for four consecutive years are subject to specific withholding tax relief-related requirements.

Key dates

15 April 2026, 14:00

15:30; - Public hearing on joint guidelines

15 April 2026, 15:30

16:30; - Public hearing on EBA RTS

25 May 2026 Deadline

- Deadline for submitting comments on joint guidelines and EBA RTS

Post

25 May 2026; - EBA publishes all contributions (unless requested otherwise)

TBD (post

consultation); - Revised guidelines enter into force, repealing 2021 guidelines

Suggested considerations

• Assess current suitability processes against new requirements (e.g., ex-ante applications, AML/CFT checks, third-country branch specs) and prepare for mandatory assessments of additional roles like CFOs.
• For large institutions, evaluate EBA RTS on documentation and align internal templates (e.g., suitability questionnaires, CVs).
• Participate in public hearings on 15 April 2026 if relevant.
• Plan governance updates, including ongoing monitoring of collective/individual suitability and corrective measures.

What changed

• - Incorporation of revised CRD requirements for large institutions, including ex-ante applications where authorities perform ex-post assessments, and mandatory suitability assessments for key roles...
• Expanded application to CRD-covered entities and MiFID II investment firms, with further specifications for third-country branches.
• Strengthened integration with AML/CFT framework, providing guidance on identifying reasonable grounds to suspect money laundering or terrorist financing risks during assessments.
• Introduction of targeted simplifications to streamline processes, reduce administrative burdens, and offer greater flexibility/clarity for institutions and supervisors.
• Parallel EBA consultation on RTS specifying standardized documentation (e.g., suitability questionnaires, CVs, internal assessments) for large institutions to ensure consistent submissions.