Key Points at a Glance
- From July 2027, the AMLR creates a uniform rulebook for money laundering prevention in all EU member states and replaces many national special regulations.
- Digital identities are moving to the center of identification, in particular national eIDs, the EUDI Wallet, and Qualified Trust Services (QTS).
- Companies benefit from standardized processes, lower costs, and better scalability, while consumers benefit from faster and simpler identification procedures.
Table of Contents
From the GwG to the AMLR
From a Patchwork to a European Rulebook
Until now, European money laundering prevention has been based on directives. Although these set goals, they must be implemented into national law by each member state. The result: 27 different interpretations and implementations. What counts as legally compliant identification in Germany can differ significantly from the requirements in France, Spain, or Italy. For internationally active banks and financial service providers, this has previously meant high costs, complex processes, and separate onboarding journeys for each market. This model ends with the AMLR. As a regulation, it applies directly in all EU member states and no longer requires national implementation. The scope for different interpretations is thereby significantly reduced.
The AMLR defines for the first time clearly which digital procedures are permitted in the future for identification in the context of money laundering prevention.
The focus is on three Europe-wide recognized methods:
- National electronic identities (eID): State-issued digital identities with a confidence level of “substantial” or “high.”
- The European Digital Identity Wallet (EUDI Wallet): By the end of 2026, every member state must provide an EUDI Wallet. In the future, citizens will be able to use digital identity credentials throughout Europe.
- Qualified Trust Services (QTS): These include, in particular, Qualified Electronic Signatures (QES) and Qualified Electronic Attestations of Attributes (QEAA), which are provided by qualified trust service providers.
Document-based procedures will remain possible, provided they meet the requirements of the ETSI standard 119 461. However, the regulatory thrust is clear: the EU is focusing on digital, interoperable, and eIDAS-compliant identities.
Why the AMLR is particularly relevant for Germany
Hardly any other European country has regulated digital identification for money laundering purposes as strictly as Germany. The German Money Laundering Act (GwG) previously essentially allowed four ways of remote identification:
- Personal identification, for example in a branch or via PostIdent
- Video-Ident via live video call with trained employees
- Use of the online ID function (eID)
- Qualified electronic signature in combination with a reference transfer
Above all, the requirements for Video-Ident shaped the market for years. According to BaFin specifications, the identity check had to be carried out in real-time by specially trained employees. Fully automated procedures or AI-supported identity checks were not recognized as an equivalent alternative for GwG-regulated use cases. This created a paradox: while modern technologies were already permitted for regulated identifications in other European countries, the German market remained largely dependent on manual Video-Ident procedures. The resulting consequences were obvious: significantly higher process costs, limited scalability, longer completion times, and an often weaker user experience.
What changes with the AMLR
Conclusion
The AMLR is far more than just another regulatory adjustment. It marks the transition from national identity models to a European digital identity ecosystem. For companies, this means less regulatory fragmentation and more scalability. For consumers, it opens up the prospect of simpler, faster, and more consistent identification processes within the entire European Union.
Particularly for Germany, the AMLR could initiate a long-awaited change. Away from cost-intensive, manual Video-Ident processes and towards modern, automated, and Europe-wide recognized digital identity solutions.
