As of 4 October 2026 apply current Czech AML duties. AMLR 2024/1624 is adopted and in force, but generally applies from 10 July 2027. Future-process preparation has its place without replacing current triggers or archives.
Three different dates
Adoption completes the relevant legislative step. Entry into force follows the final provision. Application determines when specific rules operate. AMLR article 90 generally specifies 10 July 2027; football agents and professional football clubs listed in article 3(3)(n) and (o) have 10 July 2029.
A statement that new European AML rules are “already in force” does not tell an accountant how to identify a customer today. “Everything starts in 2027” equally overlooks current Czech duties and differing schedules among EU acts.
Current Czech layer
Classify today’s service under section 2 of Act 253/2008. Apply current identification and due diligence triggers, professional exceptions and records rules. Do not decide a low-cost virtual office or occasional accounting engagement from an isolated future EU provision.
Czech legislation can change before AMLR’s general application. Decisions therefore need a legal-as-of date and particular provisions. Do not erase original verification records when updating them; they explain the earlier conclusion.
Directives and institutions
Directive 2024/1640 addresses institutional and other national matters. Article 78 has a general 10 July 2027 transposition deadline and particular deadlines in 2025, 2026 and 2029. A deadline does not prove that a particular Czech implementation has already been enacted in an assumed form. Check published Czech legislation.
AMLA has a separate institutional framework. It does not mean direct European supervision of every accountant or registered office provider. Distinguish customer rules, supervisory powers and technical or methodological specifications.
Preparing without losing evidence
Maintain a table of current duty, future provision, application date, change and responsible person. Test fields, exports and language versions with synthetic cases. Distinguish an adopted basic act from draft standards and final published implementing acts. Unverified drafts should not become mandatory current intake requirements.
Practical steps
- Verify current activity and Czech legislation.
- Identify the EU act and its dates.
- Map future changes.
- Check implementing and national links.
- Test changes while retaining historical evidence.
Illustrative scenario
An accounting firm accepts a recurring customer in October 2026. It completes current statutory checks while preparing a July 2027 change map. The future checklist is not a reason to skip current identification.
When the situation differs
A company rewrites retention periods from a future article and deletes old files in 2026 without assessing current and transitional rules. That process cannot be justified merely by future legislation.
What to document
- Act version and date
- Transition map
- Test and approval of the change
Common pitfalls
- Confusing force with application
- One date for all acts
- Treating Czech proposals as enacted facts
Frequently asked questions
May I wait until 2027?
No. Existing duties apply under the current regime.
Can I implement future rules early?
Process preparation is possible, but current requirements and processing legal bases must remain satisfied. Future application alone does not authorise unrestricted data collection.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- Handover and retention checklist · PDF / Word
- Practice obligations map · PDF / Word
- Foreign entities operating in Czechia →
Complete client information online
Where to go next
- AML duties in Czechia: where to start — First steps for an obliged entity: legal scope, customer measures, responsibilities and demonstrable records.
- AMLR 2024/1624: adopted rules and further specifications — The adopted EU act, technical standards, guidance and national links have different legal significance.
Sources and legal references
- Zákon č. 253/2008 Sb., aktuální znění od 11. 1. 2026 ↗
§ 2, § 7–9, § 16, § 21–22 · accessed 2026-10-04 - AMLR 2024/1624 ↗
Čl. 3 a 90 · accessed 2026-10-04 - Směrnice 2024/1640 ↗
Čl. 77–79 · accessed 2026-10-04
Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.