Guide · Credit brokers & lenders
Are credit brokers now AML-obliged entities?
Until recently, a consumer or mortgage credit intermediary that was not itself a bank or financial institution sat outside EU anti-money-laundering law at Union level, though some member states already covered them nationally. The new AML Regulation changes that at EU level. This guide covers exactly what changed, who it affects, and by when.
- Consumer and mortgage credit intermediaries are newly obliged under the EU AMLR
- The change applies directly across the EU, with no national transposition needed
- The compliance deadline is 10 July 2027, not immediate
What did EU AML rules require of credit brokers before this change?
Before Regulation (EU) 2024/1624, consumer credit providers and mortgage credit intermediaries that were not themselves credit institutions or financial institutions had not been subject to anti-money-laundering and counter-terrorist-financing requirements at EU Union level. That did not mean every broker operated with no oversight at all: some member states had already imposed national AML obligations on credit intermediaries because of the money-laundering and terrorist-financing risk their activity carries, so the practical starting point varied by country even before this EU-level change.
What exactly changed under the new AML Regulation (AMLR)?
Regulation (EU) 2024/1624 adds consumer credit providers and mortgage credit intermediaries that are not credit institutions or other financial institutions to the list of entities obliged to run anti-money-laundering due diligence, at EU level, for the first time. This closes a gap where a broker arranging a significant loan, sometimes larger than many bank transactions, could previously operate without the identity and due-diligence checks that a bank arranging the same lending would already be required to run.
Who counts as a 'mortgage credit intermediary' or 'consumer credit provider' here?
This covers firms and individuals who arrange or provide consumer credit or mortgage credit to a borrower without themselves being a licensed credit institution or another category of financial institution already covered by earlier AML rules. It includes independent brokers who compare and arrange loans across several lenders, and consumer credit providers operating outside the banking and financial-institution categories. It does not change the position of the lenders themselves where they are already banks or financial institutions, since those were obliged entities already.
Is every broker affected, or only some?
Not every credit intermediary is newly obliged. The regulation carves out intermediaries acting under the responsibility of one or more lenders or credit intermediaries, generally referred to as tied credit intermediaries, who remain exempt from this new obligation because the lender they act for already carries the compliance duty. If you operate independently across multiple, unrelated lenders rather than under one lender's responsibility, you are more likely to fall inside the newly obliged category. See the separate guide on the tied intermediary exemption for exactly where that line sits.
What's the compliance timeline, and when does this actually take effect?
Regulation (EU) 2024/1624 is directly applicable across all EU member states without needing national transposition, but the substantive obligations, including this expansion of obliged entities, apply from 10 July 2027. The companion directive, AMLD6, Directive (EU) 2024/1640, which covers supervisory structures rather than obliged-entity due diligence, has a phased transposition timeline running through the same date. In practical terms, this is a change to plan for over the next period rather than something that took effect the day the regulation was published.
How a broker who's newly in scope adds a due-diligence step without rebuilding their intake
The practical path is adding an identity verification and, where the loan size or borrower profile calls for it, a sanctions and PEP screening step into the existing borrower application, rather than building a separate compliance process alongside it. Since the deadline sits a few years out, a broker can pilot this on new applications now, work out which fields and checks fit their existing intake, and have it running well before the transposition date rather than scrambling close to it.
In Braigest
Add the due-diligence step to your existing loan application link
A Braigest workflow can add identity verification and AML screening to a borrower's existing application without a separate system. Screening is available from the Practice plan at €149/month.
Frequently asked questions
Do I need to comply with this right now?
The substantive obligations apply from 10 July 2027. That gives time to plan, but starting the identity and screening steps on new applications well before then is sensible rather than waiting until the deadline.
Does this apply to me if I only arrange mortgages for one bank?
If you act under the responsibility of one lender, you may fall under the tied credit intermediary exemption rather than the newly obliged category. See the separate guide on that exemption for the exact conditions.
Does this change anything for the banks and lenders I work with?
No. Banks and other financial institutions were already obliged entities under earlier AML rules. This change specifically adds intermediaries and consumer credit providers that were not already covered.
Is this an EU directive that each country implements differently?
No, this specific change is in Regulation (EU) 2024/1624, which applies directly and identically across all member states without national transposition, unlike a directive.
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