The study includes a low-cost case and tests higher-cost assumptions that we consider more realistic for planning in parts of the non-financial sector. We prepared it to contribute to the debate on regulatory proportionality and access to beneficial ownership data based on legitimate interest.
What the study measures
The AMLR generally applies from 10 July 2027. Our model estimates that the population of obliged entities could rise from 823,000 before implementation to 900,000 after implementation, with 2,000 additional financial entities and 75,000 additional non-financial entities. These are modelling assumptions. Some firms in the additional cohort may already have AML obligations under national law.
The study separates annual expenditure at existing cost rates, additional recurring expenditure under the AMLR and one-off implementation costs. The €81.66 billion baseline applies existing cost rates to the full modelled population of 900,000 entities. It provides a common benchmark for comparing scenarios. Measuring actual expenditure before implementation would require data on the 823,000 existing entities and on any costs already incurred by firms in the additional cohort.
From a low-cost case to higher-cost scenarios
A separate sensitivity analysis tests €2 billion in additional annual costs as a low-cost case and €8 billion as an upper illustrative case, alongside the central estimate of €4.14 billion. This shows how the result changes when assumptions about the additional burden in both sectors vary.
The study also tests two higher-cost scenarios that double or quadruple the assumed non-financial cost rates while holding financial-sector rates constant. We consider higher assumptions more realistic for planning in parts of the non-financial sector because budgets based on current practice can understate the time needed to review complex files, verify information, test controls and demonstrate that procedures work in practice. The multipliers show the effect of higher cost intensity. Actual costs will vary by sector, firm size, risk profile and supervisory practice.
| EU-27 expenditure | Central scenario | Non-financial rates ×2 | Non-financial rates ×4 |
| Annual expenditure at baseline cost rates | €81.66bn | €99.81bn | €136.12bn |
| Additional annual AMLR costs | €4.14bn | €6.27bn | €10.51bn |
| Illustrative annual total after implementation | €85.80bn | €106.08bn | €146.63bn |
| One-off implementation costs | €5.09bn | €8.39bn | €14.99bn |
The annual totals after implementation assume that the baseline and additional costs can be combined without overlap. The highest-cost scenario is separate from the €8 billion illustrative case and uses a different set of assumptions.
Where businesses incur the additional costs
One-off costs can arise when firms reconfigure monitoring systems, revise procedures, train staff or update existing client files. Recurring costs arise when the new framework requires more work on an ongoing basis, such as checking beneficial ownership through several layers of a structure, reviewing monitoring alerts or documenting and testing controls. The model counts the additional work compared with what firms would otherwise do under their existing obligations.
In the central scenario, financial entities account for €2.02 billion of additional annual costs and non-financial entities for €2.12 billion. For smaller businesses, a significant part of the burden may be senior staff time. Some costs may also reach clients through higher fees or prices.
The case for a full cost-benefit analysis
The study estimates gross compliance costs. The proportionality debate also needs evidence on how much the additional work improves the prevention and detection of financial crime, where harmonisation could reduce duplication, and whether more targeted measures could deliver comparable results. For access to beneficial ownership data based on legitimate interest, the analysis should consider who needs access, what information is necessary and which safeguards can protect personal data while preserving the value of legitimate scrutiny.
We call on the European Commission and the EU Anti-Money Laundering Authority (AMLA) to carry out and publish a full cost-benefit analysis of the new framework and its implementing measures. Comparable evidence by sector, firm size and risk profile would help policymakers assess where additional requirements are justified and where a more targeted approach could achieve the same outcome at lower cost.
Read the research paper
For more information, please contact office@rosemont-mc.com