Source: AMLA consultation paper draft
- Anti-money laundering
AMLR supplemental acts
- RTS on customer due diligence
Article 10 Reasonable measures for verification of the beneficial owner
This is a draft act
This text has been parsed from the AMLA consultation paper draft as published on 9 February 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.
Summary What does Article 10 of the RTS on customer due diligence say?
This article directly supports the verification requirements set out in Article 22(7), point (b), of Regulation (EU) 2024/1624, by specifying what "reasonable measures" actually look like in practice when verifying the identity of beneficial owners or persons on whose behalf a transaction is carried out.
Rather than leaving that standard undefined, the article gives obliged entities two concrete routes to choose from: consulting accessible public registers and national systems, or gathering information from the customer or reliable third-party sources.
The breadth of acceptable third-party sources is notable, ranging from credit agencies and utility bills to confirmation from other regulated financial institutions and certified documents from legal entities or arrangements.
Important points:
- Use at least one of the specified verification routes — public registers or third-party information gathering — to satisfy the reasonable measures standard for beneficial owner verification.
- When relying on information from credit or financial institutions, ensure that the information collected confirms the beneficial owner has already been identified and verified by that institution.
- Documents sourced from a legal entity or legal arrangement are only acceptable where the identity of the named beneficial owner is certified by persons authorised for document certification purposes.
Springlex's summary of the article, a reading aid, not a substitute for the legal text.
The reasonable measures referred to in Article 22(7), point (b), of Regulation (EU) 2024/1624 shall include at least one of the following:
consulting public registers, other than the central registers, or other reliable national systems that contain the information necessary to verify the identity of the beneficial owner, or the person on whose behalf or for the benefit of whom the transaction or activity is being carried out, such as the residence register, tax register, passport database and the land register, to the extent that these are accessible to obliged entities; or
collecting information from the customer or other sources, which may include third-party sources such as:
reputable credit agencies and/or comparable reputable data services providers;
utility bills;
up-to-date information from credit or financial institutions as defined in Article 3, paragraphs (1) and (2), of Regulation (EU) 2024/1624. The collected information shall confirm that the beneficial owner or the person on whose behalf or for the benefit of whom a transaction or activity is being carried out has been identified and verified by the respective institution;
documents from the legal entity or the legal arrangement where the beneficial owner is named, and where the identity of the named person is certified by persons that are authorised for document certification purposes.
Springlex and this text is meant purely as a documentation tool and has no legal effect. No liability is assumed for its content. The authentic version of this act is the one published in the Official Journal of the European Union.
Definition
crypto-asset services
Definition
financial mixed activity holding company
Definition
crypto-asset service provider
Definition
credit institution
- a credit institution as defined in Article 4(1), point (1), of Regulation (EU) No 575/2013;
- a branch of a credit institution, as defined in Article 4(1), point (17), of Regulation (EU) No 575/2013, when located in the Union, whether its head office is located in a Member State or in a third country;
Definition
crypto-asset
Definition
property
Definition
express trust
Definition
legal arrangement
Definition
financial institution
- an undertaking other than a credit institution or an investment firm, which carries out one or more of the activities listed in points (2) to (12), (14) and (15) of Annex I to Directive 2013/36/EU of the European Parliament and of the Council(32), including the activities of currency exchange offices (bureaux de change), but excluding the activities referred to in point (8) of Annex I to Directive (EU) 2015/2366, or an undertaking the principal activity of which is to acquire holdings, including a financial holding company, a mixed financial holding company and a financial mixed activity holding company;
- an insurance undertaking as defined in Article 13, point (1), of Directive 2009/138/EC of the European Parliament and of the Council(33), insofar as it carries out life or other investment-related assurance activities covered by that Directive, including insurance holding companies and mixed-activity insurance holding companies as defined, respectively, in Article 212(1), points (f) and (g), of Directive 2009/138/EC;
- an insurance intermediary as defined in Article 2(1), point (3), of Directive (EU) 2016/97 where it acts with respect to life insurance and other investment-related insurance services, with the exception of an insurance intermediary that does not collect premiums or amounts intended for the customer and which acts under the responsibility of one or more insurance undertakings or intermediaries for the products which concern them respectively;
- an investment firm as defined in Article 4(1), point (1), of Directive 2014/65/EU of the European Parliament and of the Council(34);
- a collective investment undertaking, in particular:
- an undertaking for collective investment in transferable securities (UCITS) as defined in Article 1(2) of Directive 2009/65/EC and its management company as defined in Article 2(1), point (b), of that Directive or an investment company authorised in accordance with that Directive and which has not designated a management company, that makes available for purchase units of UCITS in the Union;
- an alternative investment fund as defined in Article 4(1), point (a), of Directive 2011/61/EU and its alternative investment fund manager as defined in Article 4(1), point (b), of that Directive that fall within the scope set out in Article 2 of that Directive;
- a central securities depository as defined in Article 2(1), point (1), of Regulation (EU) No 909/2014 of the European Parliament and of the Council(35);
- a creditor as defined in Article 4, point (2), of Directive 2014/17/EU of the European Parliament and of the Council(36) and in Article 3, point (b), of Directive 2008/48/EC of the European Parliament and of the Council(37);
- a credit intermediary as defined in Article 4, point (5), of Directive 2014/17/EU and in Article 3, point (f), of Directive 2008/48/EC, when holding the funds as defined in Article 4, point (25), of Directive (EU) 2015/2366 in connection with the credit agreement, with the exception of the credit intermediary carrying out activities under the responsibility of one or more creditors or credit intermediaries;
- a crypto-asset service provider;
- a branch of a financial institution referred to in points (a) to (i), when located in the Union, whether its head office is located in a Member State or in a third country;
Definition
third country
Definition
funds
Definition
beneficial owner