EBF response to AMLA’s public consultation on the draft ITS on the Reporting of Suspicions and Providing Transaction Records

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Brussels, 22 September 2026 - The response of the European Banking Federation (EBF) to AMLA's public consultation on the draft Implementing Technical Standards (ITS) specifying the format to be used for the reporting of suspicions (SARs) and for the provision of transaction records under Article 69(3) of the AMLR supports the objective of greater harmonisation of the SAR reporting across the EU, while emphasising the need for a genuinely risk-based and proportionate approach to the information required. In our view, the current draft is disproportionate in scope, with the proposed data set extending beyond what is necessary for the effective submission and processing of SAR reports and, in some cases, beyond information that obliged entities are required or permitted to collect under the AMLR and the CDD framework. We therefore call for a clear assessment of the AML/CFT relevance and necessity of data points, with reporting requirements focused on information that is genuinely needed.

We also stress the importance of avoiding unnecessary duplication, particularly for large financial groups. The ITS should accommodate a group-wide and holistic approach to reporting suspicious activity across products, services and legal entities, while providing sufficient flexibility for future group-wide reporting models, including centralised reporting where appropriate.

Finally, the EBF calls for a stable and proportionate implementation framework that provides obliged entities with sufficient time to adapt their systems and processes and avoids unnecessary dual reporting during the transition. The framework should also be sufficiently flexible to accommodate future reporting models and support greater harmonisation across jurisdictions, while ensuring that the reporting requirements remain practical and do not create unnecessary operational burdens.