New AML Reporting Requirements Take Effect
On March 1, 2026, new requirements for submitting suspicious activity reports under Germany’s Anti-Money Laundering Act (Geldwäschegesetz, GwG) take effect. The changes specify the form, structure, and content of the reports that obligated entities must submit to the Financial Intelligence Unit (FIU).
The goal of the new reporting requirements is to achieve greater standardization and comparability of the data submitted, in order to improve the analysis of suspicious financial transactions and make processes more efficient.
What changes for obligated entities?
With the new requirements taking effect, the standards for suspicious activity reports are being further refined. This particularly affects the scope of information to be submitted, the structured capture of relevant data fields, and a stronger alignment with risk-based criteria.
Reports must continue to be submitted exclusively through the electronic reporting portal goAML. Proper registration with the FIU remains a mandatory prerequisite.
Who is affected?
The new reporting requirements apply to all entities obligated under the Anti-Money Laundering Act, including but not limited to:
- Credit and financial services institutions
- Payment and e-money institutions
- Insurance companies and certain intermediaries
- Tax advisors, auditors, and attorneys engaged in relevant activities
- Real estate agents and dealers in goods
These obligations apply regardless of whether suspicious activity reports are filed regularly or only on an occasional basis.
What are the next steps?
Once the new requirements take effect, companies must review and, where necessary, adjust their internal processes for detecting, documenting, and reporting suspicious cases. An incomplete or incorrect report can result in follow-up inquiries, delays, or regulatory consequences.
Compliance with anti-money laundering obligations is supervised by, among others, the Federal Financial Supervisory Authority (BaFin) and other competent authorities.
Obligated companies should therefore make sure they are familiar with the new reporting requirements and are technically and organizationally prepared to meet them.