Article 14 Identification and verification of beneficiaries of trusts and similar legal entities or arrangements

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 14 of the RTS on customer due diligence say?

This article builds directly on Article 22(4) of Regulation (EU) 2024/1624, specifying what information obliged entities must collect when dealing with trustees, legal entities, or legal arrangements — such as express trusts and similar structures — where beneficiaries are not yet individually identified.

The core concern is whether beneficiaries defined only by class or characteristics have become sufficiently ascertainable to be treated as beneficial owners, which triggers additional due diligence obligations.

The article also places an ongoing duty on obliged entities to stay informed of any material changes to that beneficiary picture over time.

Important points:

Obtain a description of the class of beneficiaries, with enough detail to determine whether any individual within that class has become ascertainable and must therefore be treated as a beneficial owner.
Support that description with relevant documents confirming it is correct and up-to-date.
Take risk-sensitive measures to ensure trustees, legal entities, or legal arrangements provide timely updates whenever material events occur that could cause previously unidentified beneficiaries to become ascertainable.

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

1. For the purposes of Article 22(4) of Regulation (EU) 2024/1624, the information obliged entities shall obtain from the trustee, legal entity or legal arrangement include:
  1. a description of the class of beneficiaries and its characteristics, which shall contain sufficient information to allow the obliged entity to determine whether individual beneficiaries are ascertainable and shall be treated as beneficial owners; and
  2. relevant documents to enable the obliged entity to establish that the description is correct and up-to-date.
1. Obliged entities shall take risk-sensitive measures to ensure that the trustee, legal entity or legal arrangement provide timely updates, including on specific material events that may lead to beneficiaries previously identified by class or characteristics becoming ascertainable and thus beneficial owners.

Table of contents

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