Accountio / Templates / EU AML Regulation / AMLR gap analysis

AMLR gap analysis template for accountants and auditors

Compare what your firm does under your national anti-money laundering rules with what the EU Anti-Money Laundering Regulation requires from 10 July 2027, article by article, and turn every gap into an action with an owner and a date. This AMLR gap analysis is one Excel workbook with nearly 40 requirements already filled in.

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What the gap analysis looks like

AMLR gap analysis template
What the gap analysis coversArea or column in the workbook
Whether the firm is in scope
✓
ScopeAuditors, external accountants and tax advisers, plus company and trust services
Policies, procedures and controls
✓
GovernanceWritten policies approved by the management body, and an independent audit where it fits the firm's size
The business-wide risk assessment
✓
Risk assessmentRisk factors to cover, who drafts and approves it, and new services or technology
Compliance manager and compliance officer
✓
Compliance functionsWho to appoint, the yearly report and the rule for one-person firms
Training and staff checks
✓
StaffRole-based training, and checks on skills, good repute and integrity
Client due diligence
✓
Due diligenceWhen it applies, the new identification data, verification, reviews, simplified and enhanced measures, PEPs and reliance
Beneficial owners
✓
Beneficial ownersThe 25% test, control by other means, senior managing officials and express trusts
Suspicious transaction reports
✓
ReportingReporting to the FIU, the 3 and 5 working day rules, and tipping off
Records, data and cash
✓
Records and data, CashFive-year retention, deleting personal data, and the €10,000 cash limit
Where national rules or AMLA still matter
✓
Also check (national rules or AMLA)Supervisor rules and the status of each AMLA standard
Your gaps and actions
✓
What we do now, Gap?, Action needed, Owner, Due date, StatusYes, Partly or No, with an owner and due date for every gap
What still needs work
✓
Check, SummaryMissing actions, due dates after 9 July 2027, open actions and the days left

When you need an AMLR gap analysis

The AML Regulation applies directly in every EU member state from 10 July 2027. It lists auditors, external accountants and tax advisers as obliged entities, along with anyone whose main business is giving material aid, assistance or advice on tax matters. It replaces most national anti-money laundering rules with one EU rulebook, while your supervisor stays national. Run the gap analysis when:

  • Your firm audits, keeps accounts or gives tax advice in an EU member state
  • You want a plan for the changes before 10 July 2027
  • The partners need a list of actions with owners and dates
  • Your firm also forms companies or provides a registered office
  • Your supervisor asks how you are getting ready

How to use the AMLR gap analysis

  1. Describe what you do now. For each row, write how your firm meets the point under your current national rules.
  2. Mark the gap. Choose Yes, Partly or No in the Gap? column.
  3. Plan every gap. Enter the action, an owner and a due date for each Yes or Partly. Rows without them turn red.
  4. Check the Also check column. It shows where your national law, your supervisor or a pending AMLA standard still decides the detail.
  5. Track it to the end. Mark actions Done as they finish. The Summary sheet shows open actions and the days left until 10 July 2027.

Questions

When does the EU AML Regulation apply?

From 10 July 2027. Until 9 July 2027, firms keep following their current national anti-money laundering rules.

Does the AMLR apply to accountants?

Yes. Article 3 lists auditors, external accountants and tax advisers as obliged entities, as well as any person whose main business or professional activity is giving material aid, assistance or advice on tax matters.

What does the AMLR require of an accounting firm?

Written internal policies, procedures and controls, a business-wide risk assessment, a compliance manager from the management body and a compliance officer, staff training and integrity checks, customer due diligence, reporting of suspicions to the financial intelligence unit, and record keeping.

Who is the compliance manager under the AMLR?

A member of the management body who answers for compliance with the Regulation. The management body also appoints a compliance officer who runs the day-to-day controls and reports suspicious transactions. Where the firm's size and risks justify it, one person can hold both roles.

How long must AMLR records be kept?

Five years from the end of the business relationship or the date of the occasional transaction. Personal data is then deleted, unless other law requires a longer period.

Also in the EU AML Regulation readiness pack

Business wide risk assessmentAML policies and proceduresAppointment of compliance manager and compliance officerCustomer due diligence form: individualsCustomer due diligence form: legal entitiesTraining and integrity log

See the whole pack →

Who it's for

Accounting, audit and tax firms in EU member states getting ready for 10 July 2027.

Last checked

Checked against the EU AML Regulation in November 2026.