Legal changes
What applies today, what July 2027 brings and how to prepare your business. Key dates, context and practical guidance in one place.
Use the applicable Czech AML Act No. 253/2008 and related legislation. Adoption of the EU package does not postpone today’s identification, due diligence, reporting or record-keeping duties.
Find current obligations →Applicable Czech Act ↗This is the general application date of AMLR, Regulation (EU) 2024/1624. Article 90 sets 10 July 2029 for the specified football agents and professional football clubs.
Prepare the transition →FAÚ: AMLR application dates ↗Entry into force means the legal act exists. Application determines when its rules govern conduct. A transposition deadline is addressed to the Member State.
Meet current Czech duties while preparing the transition. AMLD6’s partial transposition deadline for Articles 11, 12, 13 and 15 was 10 July 2026; this alone does not establish how Czech implementation occurred.
AMLD6 · čl. / Art. 78 ↗General AMLR application and the general AMLD6 transposition deadline. Procedures need the regulation, relevant implementing acts and applicable Czech legislation.
AMLR · čl. / Art. 90 ↗The first selection is scheduled for 2027, with direct supervision from 2028. This is not a blanket transfer of Czech bookkeeping practices or estate agencies to direct EU supervision.
AMLA: selection timetable ↗Later application for football professions under AMLR Article 90. Separately, the AMLD6 Article 18 transposition deadline falls on this date. 2029 is not a general deferral for small businesses.
AMLD6 · čl. / Art. 78 ↗Changing the name of the law in a document is not enough. Identify the effect on your service, client file and the person performing each procedure.
| Area | Future framework | What to prepare |
|---|---|---|
| Your business scope | AMLR Article 3 categories and conditions do not automatically equal today’s Czech section 2. | List actual services, countries of operation and borderline activities. Do not rely solely on your business licence title. |
| Customer due diligence | AMLR Chapter III, including relevant further rules and standards. | Map collected data, verification methods, risk scenarios and exception approvals. Distinguish questionnaires from checks actually performed. |
| Risk and internal governance | Internal policies and controls under AMLR Chapter II. | Prepare risk assessment, accountable roles, escalation, training and review records. Check that documented procedures reflect actual work. |
| Ownership and changes | Beneficial ownership rules and related due diligence. | Document ownership chains and triggers for updating a client file. A register extract is not the entire procedure. |
| Reporting and records | EU requirements together with relevant Czech institutional rules. | Version forms, permissions, secure transfers and records. Verify future Czech reporting channels before changing live operations. |
Legal basis: AMLR, especially Chapters I–V ↗ The final column is an editorial preparation recommendation, not a new list of statutory duties.
The filter provides orientation. Verify each instrument’s scope against actual activities and exceptions.
Adopted, general application is still in the future
Compare current Czech procedures with new EU rules on scope, due diligence and internal organisation. Current obligations remain the separate basis until transition.
Create a gap list. Assign each gap a document, accountable role, deadline and scenario test.
Affected records: Obligations map, risk assessment, internal policies, training
Open related template →Adopted future framework
Recheck whether forms and procedures capture ownership and control under the new framework. Do not replace today’s percentage test with future rules without distinguishing dates.
Prepare comparison cases for direct holdings, chains and other influence. Review data fields, instructions and evidence.
Affected records: Client form, ownership diagram, owner-verification procedure
Open related template →Legislative preparation; final wording must be verified
FAU communication on ZEOS and related legislation is not itself an adopted law. Check scope, reporting channels and transitional provisions against the promulgated text.
Distinguish proposal, adoption, promulgation and application. Track actions dependent on final Czech wording.
Affected records: Legal obligations matrix, contacts, reporting, change log
Open related template →Selection in 2027, direct supervision from 2028
Concerns selected financial entities; do not assume direct AMLA supervision of every accounting or property practice.
A financial group checks selection criteria and data readiness. A non-financial firm follows relevant rules and its sector supervisor.
Affected records: Supervisory map, data outputs, internal responsibilities
Open related template →AMLA: výběr pro přímý dohled / selection for direct supervision ↗
Adopted deferred application
The special date concerns professional football clubs and agents specified in AMLR. It does not postpone the entire package until 2029.
Check the category’s exact scope, transactions and statutory exemptions; assess current obligations from other activities separately.
Affected records: Activity classification, onboarding, transaction procedures
Open related template →Current operational task
Sanctions changes, a different owner or a new service can require action now. The 2027 timetable does not justify delaying current checks.
Record the trigger, affected clients and documents, response and effectiveness check. Reading a newsletter alone does not implement a measure.
Affected records: Review record, sanctions report, document versions
Open related template →— Added practical implications, an audience filter, linked records and a distinction between adopted rules and Czech legislative preparation.
Further updates will carry a date and description. This is an editorially maintained overview, not continuous legal monitoring.
A suggested working plan. Adapt its sequence and capacity to your business size and risks; these are not separate statutory deadlines.
List services, client groups, responsibilities, templates and systems. Assign an owner and locate the current description of each procedure.
Output: an activity and document map.For each change, record the current rule, future provision, verification status, impact and application date. Keep unresolved questions open with a specific next action.
Output: a sourced change register.Translate verified differences into forms, internal policies and software requirements. Keep current operational versions separate from prepared future versions.
Output: versioned documents and a rollout plan.Walk through a new client, unclear ownership, a risk scenario and changed information. Test escalation, permissions and decision traceability as well as forms. Use synthetic data.
Output: test records and a correction list.Recheck legal dependencies before transition, complete training and assign approval of the new version. Record the launch date and the process for handling discovered errors.
Output: an approved procedure, training records and a post-launch review.Adapt these working outlines to your activities. Downloading or ticking a checklist does not certify compliance.
Each article develops a specific part of the transition with steps, an example, common mistakes and sources. You do not need to start by reading the entire EU regulation.
Start here to distinguish adopted rules, application dates and supervisory responsibilities.
Current Czech duties and future AMLR application; distinguish adoption, entry into force and application.
The adopted EU act, technical standards, guidance and national links have different legal significance.
Direct European supervision of selected financial entities and implications for smaller Czech obliged entities.
Move from a list of differences to updated procedures, internal policies and training, including in a small practice.
Plan process, data and supplier changes without prematurely replacing current duties.
A practical map of clients, products, channels and geography with measures matching actual activities.
Turning an outline into usable staff procedures with responsibilities, escalation and evidence.
Who needs training, when to repeat it and how to demonstrate attendance and content.
Not every change waits until 2027. Client information, sanctions lists and legal sources can require action today.
Check applicability, scope, exact provisions and review quality rather than a pages date.
Historical evidence, current screening and assessment of changes are separate file elements.
Record representatives, ownership and purpose changes while verifying them and preserving earlier evidence.
Current client work must follow current rules. Prepare the future version separately. Determine the changes by comparing the actual procedure with the applicable legislation.
If the activity falls within AML scope, small size alone is not a reason to skip preparation. Use the professions directory to check your activities, conditions and exceptions. The same approach applies to other professions, including company service providers.
No. The reform does not suspend current sanctions rules or the need to respond to client changes. An earlier check records the query and source version used at that time, not permanent absence of risk.
No. It helps you understand the framework and build a plan. Readiness requires completed actions, verified applicable rules and tested procedures suited to your services.
