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AMLA final report: draft ITS on reporting the results of joint analyses to the EPPO

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On 3 July 2026, the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) published its final report containing draft Implementing Technical Standards under Article 41(2) of Regulation (EU) 2024/1620, the AMLA Regulation or AMLAR.

Article 41(1) requires AMLA to report without undue delay to the European Public Prosecutor’s Office (EPPO) where the results of an AMLA-coordinated joint analysis provide reasonable grounds to suspect money laundering or other criminal activity in respect of which the EPPO could exercise its competence. The report must include the joint-analysis results and any additional relevant information.

The draft ITS would standardise how AMLA makes those reports. It provides a nine-section sample reporting template, distinguishes mandatory from discretionary fields, requires a secure electronic communication channel and regulates how restrictions on the subsequent use of information must be recorded. Reports would ultimately have to be submitted in a machine-readable format capable of automatic processing by the EPPO.

This is AMLA’s final draft, not yet a binding Commission implementing regulation. As of 23 September 2026, European Commission adoption and publication in the Official Journal remain pending. The embedded draft proposes general application from 10 July 2027 and application of the machine-readable reporting requirement from 10 July 2028.

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Key takeaways

  • AMLA has completed its work on the draft ITS and published a final report, but Commission adoption remains pending.
  • The instrument implements Article 41(2) AMLAR and governs reporting by AMLA, not reporting by individual FIUs or private obliged entities.
  • Reporting is triggered where a joint analysis provides reasonable grounds to suspect conduct in respect of which the EPPO could exercise its competence.
  • The annex contains a nine-section sample template covering case information, suspected offences, potential suspects, financial analysis, findings, use restrictions and urgent measures.
  • Mandatory fields must be completed where AMLA holds the required information; supporting documents may still be attached in non-machine-readable form.
  • AMLA and the EPPO may use any secure electronic channel that protects confidentiality and integrity; the draft does not mandate FIU.net.
  • AMLA must specify whether reported information may be used without restriction or for one or more specified permitted purposes, or subject to other expressly stated restrictions.
  • The draft expressly imposes no direct obligations on private entities.

What changed

AMLA has moved the Article 41(2) mandate from consultation to final-report stage and submitted the resulting draft ITS to the European Commission.

The draft Commission implementing regulation contains seven articles and an annexed sample reporting template. It establishes rules on the report format, completion of mandatory and discretionary fields, communication channels and restrictions on the use of reported information.

The template is organised into nine sections: general information; place, time, damage and type of suspected offence; executive summary; potential suspects; description of the case; financial analysis; findings and conclusions; restrictions on use; and urgent measures.

Following the May 2026 public hearing and further working-group discussions, AMLA adjusted field names and postponed application of the machine-readable reporting requirement until 10 July 2028. AMLA reported that hearing participants raised no major concerns with the overall approach.

The final draft retains a technologically neutral transmission model. FIU.net could be used in the future, but the operative requirement is for a secure electronic channel that safeguards the confidentiality and integrity of the information.

Why it may matter

A standardised reporting structure should help the EPPO receive more complete and comparable information from AMLA-coordinated joint analyses, reducing manual processing and avoidable follow-up requests.

The machine-readable requirement is intended to support automatic processing and integration into the EPPO’s case-management systems. The delayed application date gives AMLA and the EPPO additional time to adapt their systems and operational processes.

The instrument also addresses a legally sensitive aspect of financial-intelligence cooperation: information supplied by participating FIUs may be subject to restrictions under Union or national law. Recording those restrictions explicitly is intended to support lawful onward use while preserving trust among AMLA, participating FIUs and the EPPO.

For private-sector compliance professionals, the development is principally relevant as part of the EU’s institutional enforcement architecture. It does not create a new reporting duty for banks, payment institutions, crypto-asset service providers or other obliged entities.

Who may be affected

Financial Intelligence UnitsOther affected stakeholders

AMLA is the sole formal reporting entity under this draft ITS, while the European Public Prosecutor’s Office is the intended recipient.

National Financial Intelligence Units may be operationally affected because the reports concern joint analyses conducted by AMLA together with FIUs. Information supplied by participating FIUs may be included in the reporting template, and restrictions arising under the relevant national law must be respected.

European Delegated Prosecutors, national judicial or prosecutorial authorities and other authorities involved in related investigations may also be indirectly relevant. The template includes fields concerning national criminal investigations, existing EPPO involvement and urgent measures.

The draft concerns institutional communication between AMLA and the EPPO. It imposes no direct obligations on private obliged entities, their management or their compliance teams.

Practical considerations

  • Track European Commission adoption and Official Journal publication; do not treat the final report as binding EU law.
  • Keep this development distinct from the Article 81(1) AMLR ITS governing reports made directly by national FIUs to the EPPO.
  • Monitor whether the Commission changes the reporting fields, application dates or communication-channel provisions before adoption.
  • Map the nine template sections to the data and analysis outputs generated through AMLA-coordinated joint analyses.
  • Establish data-quality controls for mandatory fields, including case references, suspected offences, estimated damage, persons, legal entities and financial flows.
  • Ensure that any electronic transmission channel protects both confidentiality and integrity.
  • Record restrictions on use in a manner that reflects applicable Union law and the national law governing information supplied by participating FIUs.
  • Develop procedures for identifying urgent measures, including account or transaction suspensions and risks involving imminent loss of evidence or movement of funds.
  • Prepare for machine-readable reporting and automatic EPPO processing, while recognising that the draft allows supporting material to remain non-machine-readable.
  • Reassess implementation planning once the Commission act is adopted and its final application provisions are known.

These considerations support professional review and do not constitute legal advice.

Development timeline

  1. Milestone date not established

    Final report published

    Publication of a final report does not itself establish adoption or entry into force of the instrument.

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    Milestone verified by AML Agent: .

AMLAR Article 41(1)AMLAR Article 41(2)Regulation (EU) 2024/1620Regulation (EU) 2017/1939Directive (EU) 2017/1371Article 40 of Regulation (EU) 2024/1620 — AMLA-coordinated joint analysesArticle 41(1) of Regulation (EU) 2024/1620 — reporting joint-analysis results to the EPPOArticle 41(2) of Regulation (EU) 2024/1620 — mandate for the draft ITSArticle 47 of Regulation (EU) 2024/1620 — FIU.netArticle 53 of Regulation (EU) 2024/1620 — Commission adoption procedure for ITSArticles 22 and 25(2)–(3) of Regulation (EU) 2017/1939 — EPPO competenceDirective (EU) 2017/1371 — criminal offences affecting the Union’s financial interests

Official sources