The European Union’s Anti-Money Laundering Authority (AMLA) has launched a targeted survey of payment service providers and electronic money institutions to evaluate their experience with central contact point (CCP) requirements, as the agency prepares to refine the regulatory framework governing cross-border financial operations
Survey Launch and Objectives
AMLA initiated the survey on Thursday, August 6, 2026, as part of its preparatory work for developing draft Regulatory Technical Standards under Article 41(2) of the Anti-Money Laundering Directive (AMLD). The initiative aims to collect practical insights from payment firms and e-money institutions regarding their implementation of existing CCP arrangements across EU member states.
The feedback gathered through this exercise will enable AMLA to assess how effectively central contact point mechanisms have functioned in practice, identify operational challenges faced by institutions, and determine areas where the framework may require adjustment or clarification. In parallel with the industry survey, AMLA is conducting a separate consultation with national competent authorities to gather supervisory perspectives on CCP effectiveness and enforcement.
Understanding Central Contact Point Requirements
Central contact points serve as designated liaison entities that foreign payment service providers and electronic money issuers must appoint when operating in EU member states where they do not maintain a subsidiary or branch establishment. The requirement applies to firms operating through agents, distributors, or other infrastructure under the freedom to provide services across borders.
Under current EU regulations, host member states may require the appointment of a CCP when specific criteria are met, including scenarios where a firm maintains ten or more establishments in the territory, or where cumulative transaction volumes exceed €3 million per financial year. Additional triggers include situations where information necessary to assess compliance with these thresholds is not made available to host authorities in a timely manner.
The central contact point functions as the primary interface between the obliged entity and local supervisory authorities, ensuring compliance with anti-money laundering and counter-terrorist financing (AML/CFT) rules applicable in the host member state. CCPs are responsible for facilitating supervisory oversight, providing requested documentation and information to authorities, and supporting on-site inspections of agents operating under the right of establishment.
Regulatory Context and Timeline
The current CCP framework stems from Commission Delegated Regulation (EU) 2018/1108, which supplemented the Fourth Anti-Money Laundering Directive with regulatory technical standards specifying criteria for CCP appointment and defining their functions. This regulation established binding requirements directly applicable across all EU member states, creating a harmonized approach to cross-border supervision of payment and e-money services.
AMLA’s mandate to develop updated regulatory technical standards follows provisions in the revised Anti-Money Laundering Regulation (AMLR), which requires the authority to submit draft standards to the European Commission by July 10, 2026. The new framework will extend CCP requirements to include crypto-asset service providers, addressing a gap in the previous regulatory regime that did not cover digital asset businesses.
The survey explicitly excludes crypto-asset service providers from its current scope, as the previous CCP framework did not apply to this sector. However, the forthcoming regulatory technical standards will incorporate these e
Industry Implications and Compliance Considerations
Payment firms and e-money institutions operating across multiple EU jurisdictions face significant compliance obligations under the CCP framework. The requirement to appoint local representatives adds operational complexity and cost, particularly for firms utilizing agent networks or distributor arrangements rather than establishing full branch operations.
Industry stakeholders have reported varying interpretations of CCP requirements across member states, with some national authorities implementing more stringent thresholds or additional obligations beyond the baseline EU standards. This regulatory divergence has created compliance challenges for cross-border operators, who must navigate differing national implementations while maintaining consistent AML/CFT controls across their EU footprint.
The survey results will inform AMLA’s approach to harmonizing CCP requirements, potentially reducing fragmentation and creating more predictable compliance obligations for payment service providers operating in multiple jurisdictions. Enhanced clarity on CCP functions and appointment criteria could streamline supervisory processes while maintaining effective oversight of cross-border financial activities.
Supervisory Coordination and Enforcement
Central contact points play a critical role in facilitating coordination between home and host member state supervisors, particularly in cases where payment institutions operate through agent networks spanning multiple jurisdictions. CCPs must ensure that establishments comply with host member state AML/CFT rules while maintaining alignment with home state supervisory requirements.
The framework enables competent authorities to request documentation and information directly from CCPs, reducing administrative burdens associated with cross-border information exchange. CCPs also facilitate on-site inspections by host authorities, providing logistical support and ensuring access to relevant operational information during supervisory visits.
AMLA’s parallel survey of national competent authorities will capture supervisory experiences with CCP effectiveness, including cases where the mechanism has enhanced oversight capabilities or where limitations have been encountered. This dual-perspective approach—combining industry feedback with supervisory insights—aims to produce balanced regulatory technical standards that address practical implementation challenges while maintaining robust AML/CFT controls.
Broader AML/CFT Reform Context
The CCP survey forms part of AMLA’s broader preparatory work for implementing the EU’s comprehensive AML/CFT reform package, which includes the Anti-Money Laundering Regulation (AMLR) and the sixth Anti-Money Laundering Directive (AMLD6). These reforms establish a single EU rulebook for anti-money laundering requirements, with AMLA serving as the central coordinating authority for supervision and enforcement.
Industry surveys conducted in 2026 indicate growing compliance pressure on financial institutions preparing for the July 2027 implementation deadline for the new AML/CFT framework. PwC’s EMEA AML Survey 2026 revealed a gap between institutional confidence in AML/CFT preparedness and concrete action taken to address upcoming regulatory changes.
AMLA’s proactive engagement with industry stakeholders through targeted surveys demonstrates the authority’s commitment to evidence-based rulemaking, ensuring that regulatory technical standards reflect practical operational realities while maintaining effective AML/CFT controls. The agency’s approach aligns with broader EU efforts to create a more integrated and efficient financial crime prevention framework across the single market.