As part of the establishment of the European Anti-Money Laundering Authority (AMLA), the ACPR is collecting information to identify which entities will fall within AMLA's supervisory perimeter from 2028. This is referred to as the C6P collection ("Collecte en vue de l'éligibilité").
Three populations are in scope:
Groups with subsidiaries, branches, or LPS passports active in five or more EU Member States (beyond France). Only the group head entity located in France must submit the report on behalf of the group.
Standalone institutions (not part of a group) holding free establishment (LE) or LPS passports in five or more EU Member States.
Groups whose head entity is a holding company not yet subject to AML obligations — in this case, a designated obliged entity within the group must file on the group's behalf.
In all cases, whether passports are actively used or not is irrelevant to the reporting obligation: all passports must be declared.
The C6P data will be used in two ways. First, all entities and groups active in six or more Member States will be subject to annual AMLA supervisory levies — with entities under direct supervision paying five times more than those under indirect supervision. Second, among this population, forty entities assessed as "high residual risk" will be selected for direct AMLA supervision starting in 2028.
The risk methodology is defined in the draft RTS under Article 12 of the AMLA Regulation, currently under review by the European Commission. LPS thresholds triggering activity in a Member State are set at 20,000 clients or €50 million in inbound and outbound transactions.
All reported data must reflect the position as of 31 December 2025, covering the full 2025 financial year.
The filing template is the Excel file made available by AMLA. This is the only accepted format. The file must be submitted via ONEGATE to the ACPR no later than 30 June 2026.
AMLA is hosting a public webinar on 10 June 2026. Questions can be submitted via the AMLA event page until 5 June 2026.
Questions about your ACPR reporting setup or ONEGATE submissions? Contact our team.
