5AMLD implementation and disclosure in EU member states

Three dates mark the record.

• 10 January 2020. The deadline in Article 4 of Directive (EU) 2018/843 passed.
• 22 November 2022. The Court of Justice struck out public access to beneficial ownership registers.
• 7 May 2025. Hungary received the last 5AMLD letter in the Commission's published packages, on who may see its register.

5AMLD, also written 5th AMLD, amended the 2015 AML/CFT directive and reached firms only through national AML laws.

What did the 5th Money Laundering Directive ask member states to implement, and by when?

Article 4(1) set one deadline for the whole text, and the amended Article 67(1) of the 2015 directive staggered the registers.

• 10 January 2020, the law itself. Every amendment, including registration of crypto exchange and custodian wallet providers (Article 47(1)).
• 10 January 2020, company registers. A central register of each company's beneficial owners (UBO), the register most later cases turn on.
• 10 March 2020, trust registers. The same for trusts and similar arrangements.
• 10 July 2020, the prepaid card rule. Article 12(3), on anonymous cards issued outside the EU.
• 10 September 2020, bank account mechanisms. Central systems that name who holds or controls bank and payment accounts and safe deposit boxes.
• 10 March 2021, interconnection. The Commission and member states link the national registers.

Two requirements fell under the general deadline: each member state's list of the functions that make people politically exposed persons (PEPs), which PEP screening relies on (Article 20a), and enhanced due diligence (EDD) for the high risk third countries the Commission lists (Article 18a).

What happens when a member state fails to implement an EU directive?

A directive binds governments, so the Commission enforces it against member states through the infringement procedure. The Commission's infringement procedure page sets out the steps: a letter of formal notice that asks for a detailed reply, a reasoned opinion if the country is still failing its obligations, then a possible referral to the Court of Justice. "Most cases are settled before being referred to the court."

The 5AMLD letters ran on that clock. Those of 12 February 2020 gave the eight member states that had notified nothing two months to answer; those of 14 May 2020, sent for partial transposition, gave "four months". No 5AMLD case in the published packages went past the reasoned opinion.

Table 1. The infringement procedure, stage by stage (Commission page, read 30 October 2026)

Which member states missed the 5AMLD deadline?

Cyprus is the clearest case. Written to on 12 February 2020 for "not having notified any implementation measures", it received a reasoned opinion on 30 October 2020, still with nothing notified.

The two 2020 rounds name 16 member states and the UK, 17 countries in all:

• No measures notified, 12 February 2020. Cyprus, Hungary, the Netherlands, Portugal, Romania, Slovakia, Slovenia and Spain.
• Partial transposition, 14 May 2020. Belgium, Czechia, Estonia, Ireland, Greece, Luxembourg, Austria, Poland and the UK.

The UK's 2019 amending regulations took effect on 10 January 2020, with the prepaid card rule due from 10 July 2020 and a bank account portal from 10 September 2020. The May letter still counted the UK as partial.

Reasoned opinions for incomplete laws followed: on 9 June 2021 to Hungary, the Netherlands and Poland, over gaps such as anonymous accounts and trust ownership, and on 12 November 2021 to Ireland, over identifying who holds bank and payment accounts and safe deposit boxes.

In COM(2024) 112 the Commission reported transposition "has currently been declared complete by all the Member States", its completeness check done "at the end of 2022". On missing measures: "In five cases, the proceedings reached the stage of reasoned opinion. None of these cases currently remain open." Germany, Denmark, Croatia, Lithuania, Malta, Finland and Sweden appear in no published 5AMLD decision.

Which 5AMLD rules did national laws get wrong?

A law declared complete could still be wrong, and from November 2021 the Commission's letters turned to what each national text said.

Table 2. What the Commission found in national 5AMLD laws (packages of 12 November 2021 to 7 May 2025)

Most rows concern beneficial ownership registers: who must file (Romania's exemptions, Slovakia's filings, France's missing legal forms), whether the register works (Czechia, Spain, Italy) and whether wrong data costs anything (Cyprus, Romania). The January 2023 letters to Spain and Italy gave the reason: market confidence "depends largely on the existence of an accurate disclosure regime".

Provider registration forms the second group (Italy, Latvia, Hungary, Bulgaria), with crypto providers named for Latvia and Hungary. Among these rows only Portugal's covers third country prepaid cards and high risk country information, and FIU access or exchange appears for Portugal, Latvia and Slovakia.

COM(2024) 112 counted four non conformity cases at letter stage on 15 September 2023, fewer than the letters these packages list by then. Each row shows the latest published step; a case may have closed since.

How did member states handle public disclosure of beneficial owners after 2022?

On 22 November 2022 the Court of Justice held invalid the 5AMLD rule giving any member of the general public access to the beneficial ownership information of companies and other legal entities. The registers and access by authorities and obliged entities were not at issue.

AMLD6, Directive (EU) 2024/1640, rewrote the access rule of the 2015 directive in its Article 74: authorities and FIUs see everything, obliged entities see the register within customer due diligence, and anyone who can show a legitimate interest sees at least the owner's name, month and year of birth, nationality, country of residence and the interest held. That was due by 10 July 2025, and the access rules of Articles 11 to 13 and 15 by 10 July 2026.

The Commission's letter to Hungary of 7 May 2025 asked for private equity fund owners in the register and access "to any person or organisation that can demonstrate a legitimate interest", the words of Article 74.

For a firm, the file that counts is its own check of each ultimate beneficial owner.

complead, formerly Sanction Scanner, reads a register entry as a declaration that still needs checking: its KYB and UBO verification confirms the company against official registers, resolves ownership up and down the chain and shows where every field came from, and the reviewer decides what the file records.

How were the crypto and prepaid card rules applied?

Crypto providers: from registration to MiCA

Latvia had declared its law complete, yet on 15 February 2023 the Commission found custodian wallet providers missing from its obliged entities. On 28 September 2023 Hungary was told its law did not require exchange providers between virtual and fiat currencies to register or hold a license.

Article 47(1) asked only that crypto providers be "registered". In the 2022 survey reported in COM(2024) 112, most member states had added virtual asset service providers to their obliged entities, and none had a register of crypto asset accounts.

The rules then moved to EU level. Crypto transfers gained the travel rule through Regulation (EU) 2023/1113, whose amendments to the 2015 directive were due by 30 December 2024; Belgium, Spain, Poland and Portugal received letters for missing them on 17 July 2025.

Providers working under national law could continue only "until 1 July 2026" at the latest under Article 143(3) of Regulation (EU) 2023/1114, MiCA. After that they need the authorization.

Anonymous prepaid cards from outside the EU

On 9 June 2021 the Commission found that Poland had not transposed rules on "the use of anonymous prepaid cards issued in third countries". Portugal's reasoned opinion of 19 May 2022 named the same gap for credit and financial institutions.

The rule was narrower than a ban. From 10 July 2020, Article 12(3) let acquirers accept such cards only "where such cards meet requirements equivalent" to the EU's limits, and let each member state refuse anonymous prepaid card payments altogether.

What must member states transpose next?

AMLD6 must be in national law by 10 July 2027 (Article 78), and its single access point to real estate information (Article 18) by 10 July 2029. On 10 July 2027 Directive 2015/849 is repealed with every 5AMLD amendment (Article 77), and the AMLR, Regulation (EU) 2024/1624, applies directly with no transposition; football agents and professional football clubs follow on 10 July 2029 (Article 90).

6AMLD, a separate act, is Directive (EU) 2018/1673 on money laundering offenses. In 2026 the Commission sent letters under it to Germany, France and Austria (29 April) about definitions and the liability of legal persons.

What changed after 5AMLD in 2026

• 30 January 2026. Hungary received a letter under MiCA over a national authorization regime for "exchange validation services" that MiCA does not provide for.
• 12 February 2026. The FCA's cryptoasset page, updated that day, says crypto firms must still register with the FCA and expects a new UK regime, if draft law passes, on 25 October 2027.
• 29 April 2026. Spain and Poland received reasoned opinions for not transposing the Transfer of Funds Regulation's amendments to the 2015 directive.
• 1 July 2026. The longest MiCA transitional period for national crypto providers ended.
• 10 July 2026. AMLD6's register access articles, legitimate interest access included, fell due.

For this week.

1. For each EU market you onboard in, confirm how its register gives obliged entities access under the AMLD6 rules due on 10 July 2026.
2. Check each EU crypto counterparty for a MiCA authorization.
3. Map every policy clause that cites a national 5AMLD law to its AMLR article before 10 July 2027.

How this page was checked. On 30 October 2026 the author read Directives (EU) 2018/843 and 2024/1640, Regulation (EU) 2024/1624, Article 143 of MiCA, COM(2024) 112, the Court's press release 188/22, the infringement procedure page and the Commission's 47 infringement packages from February 2020 to October 2026. Ufuk Gürdaş, Compliance Specialist, fact checked it. Last reviewed: 30 October 2026.