Does the AMLR apply to AIS and PIS providers?
The AMLR draws a line that many open banking providers are missing: account information service providers fall outside the Regulation, payment initiation service providers fall squarely within it. The AMLR applies from 10 July 2027 and replaces national frameworks such as the Dutch Wwft.
Status · last updated 7 October 2026.
AIS out, PIS in.
One Regulation, two opposite outcomes for open banking licences.
AIS providers are not subject to the AMLR. Article 2 of the Regulation explicitly excludes account information service providers from the definition of “financial institution”. That means no CDD obligations, no suspicious transaction reporting and no AMLR governance requirements — for AIS activities.
PIS providers are subject to the AMLR. As payment service providers under PSD2, PISPs qualify as “financial institutions” under the AMLR. All obligations apply in full.
Three practical starting points.
Confirm your current Wwft position until 2027, and plan the transition to your AMLR-exempt status.
Make sure your compliance framework clearly separates obligations per licence type — and document it.
Run a gap analysis against AMLR requirements, prioritising the shift from reporting “unusual” to “suspicious” transactions.
Questions about the AMLR and open banking.
Are AIS providers subject to the AMLR?
No. Article 2 of Regulation (EU) 2024/1624 explicitly excludes account information service providers from the definition of “financial institution”. For AIS activities there are no CDD obligations, no suspicious transaction reporting and no AMLR governance requirements.
Are PIS providers subject to the AMLR?
Yes. As payment service providers under PSD2, payment initiation service providers qualify as “financial institutions” under the AMLR, and all obligations apply in full from 10 July 2027.
When does the AMLR start to apply?
From 10 July 2027. The Regulation replaces national anti-money-laundering frameworks such as the Dutch Wwft. On 1 October 2026 AMLA published its final reports on the technical standards for customer due diligence (Article 28 AMLR), business relationships and linked transactions (Article 19 AMLR) and group-wide requirements; once adopted by the Commission, these apply six months after entry into force.