# AMLR Art. 28 — RTS on CDD information > AMLA's RTS deadline is 10 July 2026, one year ahead of AMLR's general application date of 10 July 2027. GwG Art. 17 Abs. 1's TJPG Annex amendment is in force 1 October 2026. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.10 - Customer due diligence|FATF R.10]] - **Swiss provisions:** [[GwV-FINMA Art. 44 - Required information|GwV-FINMA Art. 44]], [[VSB 20]] - **Detailed citation:** GwV-FINMA Art. 44 ff. ## What it requires By 10 July 2026, AMLR Art. 28 requires AMLA to draft regulatory technical standards, for Commission adoption, specifying the customer due-diligence information to be collected for standard, simplified and enhanced diligence (including minimum requirements for lower-risk situations), the simplified-diligence measures available in lower-risk situations, risk factors bearing on the electronic-money exemption, reliable independent verification sources, and required attributes of electronic identification means. These standards must rest on inherent service risk, customer-category risk, transaction nature/amount/recurrence, and the channels used. ## Swiss position GwG Art. 17 Abs. 1 delegates concretisation of due-diligence duties by ordinance to FINMA (for Art. 2 Abs. 2 Bst. a-dquater intermediaries), ESBK, EJPD or BAZG depending on category; Abs. 2 lets these authorities recognise self-regulation. GwV-FINMA Art. 44, in Title 5, sets the minimum particulars collected at the start of a relationship: for natural persons/sole proprietors, name, date of birth, residential address and nationality; for legal entities/partnerships, name and registered address (Abs. 1-2), plus authorisation and representative-identity checks for entities (Abs. 3), trustee identification for trusts (Abs. 4), and rules for minors' relationships (Abs. 5). [[Scope note — GwV-FINMA Title 5 vs VSB 20]]: Title 5 binds only fintech-licence holders, portfolio managers, trustees and DLT trading systems; for banks and securities firms the same information duties are delivered instead by VSB 20 via GwV-FINMA Art. 35. ## Key divergences AMLR Art. 28 delegates this specification to one EU-level technical-standards instrument covering all obliged-entity categories uniformly, including simplified-diligence measure types, e-money exemption risk factors, and eID attribute lists. Switzerland delegates the equivalent concretisation to ordinance-making generally (GwG Art. 17), split by supervisory addressee rather than issued as one instrument, and the content itself is two-tracked: GwV-FINMA Art. 44 (Title 5) applies only to fintech-licence firms, portfolio managers, trustees and DLT trading systems, while banks and securities firms are referred instead to VSB 20, a private Swiss Bankers Association agreement not published on Fedlex. GwG Art. 17 Abs. 1's introductory sentence was narrowed by the TJPG Annex to reference only the financial-intermediary section of Chapter 2, reflecting the new adviser sections added alongside it - an institutional rather than substantive change. ## Effective dates AMLA's RTS deadline is 10 July 2026, one year ahead of AMLR's general application date of 10 July 2027. GwG Art. 17 Abs. 1's TJPG Annex amendment is in force 1 October 2026. See [[Effective-dates timeline]]. ## Further connections *These links come from an article-by-article comparison of the primary texts. They add to the provisions listed at the top of this note and make no equivalence claim.* - [[GwV-FINMA Art. 35 - Identification, controlling person and beneficial|GwV-FINMA Art. 35]] — GwV-FINMA Art. 35 refers banks and securities firms to VSB 20 for identifying the contracting party and establishing the controlling person and beneficial owner, so the detailed information duties for banks sit in a private SBA agreement; AMLR Art. 28 instead mandates AMLA technical standards (also on simplified measures, reliable sources and eID attributes). *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 28 — English text (EUR-Lex, CELEX 32024R1624) > **Article 28** > *Regulatory technical standards on the information necessary for the performance of customer due diligence* > 1. By 10 July 2026, AMLA shall develop draft regulatory technical standards and submit them to the Commission for adoption. Those draft regulatory technical standards shall specify: > (a) the requirements that apply to obliged entities pursuant to Article 20 and the information to be collected for the purpose of performing standard, simplified and enhanced due diligence pursuant to Articles 22 and 25 and Articles 33(1) and 34(4), including minimum requirements in situations of lower risk; > (b) the type of simplified due diligence measures which obliged entities may apply in situations of lower risk pursuant to Article 33(1) of this Regulation, including measures applicable to specific categories of obliged entities and products or services, having regard to the results of the risk assessment at Union level conducted by the Commission pursuant to Article 7 of Directive (EU) 2024/1640; > (c) the risk factors associated with features of electronic money instruments that should be taken into account by supervisors when determining the extent of the exemption under Article 19(7); > (d) the reliable and independent sources of information that may be used to verify the identification data of natural or legal persons for the purposes of Article 22(6) and (7); > (e) the list of attributes which electronic identification means and relevant qualified trust services referred to in Article 22(6), point (b), must feature in order to fulfil the requirements of Article 20(1), points (a) and (b), in the case of standard, simplified and enhanced due diligence. > 2. The requirements and measures referred to in paragraph 1, points (a) and (b), shall be based on the following criteria: > (a) the inherent risk involved in the service provided; > (b) the risks associated with categories of customers; > (c) the nature, amount and recurrence of the transaction; > (d) the channels used for conducting the business relationship or the occasional transaction. > 3. AMLA shall review regularly the regulatory technical standards and, if necessary, prepare and submit to the Commission the draft for updating those standards in order, inter alia, to take account of innovation and technological developments. > 4. Power is delegated to the Commission to supplement this Regulation by adopting the regulatory technical standards referred to in paragraphs 1 and 3 of this Article in accordance with Articles 49 to 52 of Regulation (EU) 2024/1620. ## Sources - AMLR Art. 28 — CELEX 32024R1624 - GwV-FINMA SR 955.033.0, Art. 44 - GwG SR 955.0, Art. 17 - GwG Art. 17 Abs. 1 amendment — sources/raw/tjpg.txt - VSB 20 (Vereinbarung vom 13. Juni 2018)