The European Union is introducing a revolution in buyer identification
The European Union is preparing a fundamental change to the rules for high-value transactions. The new AML regulation (Anti-Money Laundering), which is due to enter into force in mid-July 2027, will introduce an obligation to carry out detailed identity verification of customers, including providing their PESEL number (the Polish national identification number). The rules will apply simultaneously in all member states, which means that Poland will not be able to modify or postpone them.
The main aim of the regulation is to combat financial crime, and money laundering in particular. Until now, differences between the national laws of individual EU states have made it easier for criminals to exploit legal loopholes. Brussels wants to change this by introducing uniform, standardised customer identity verification procedures for transactions exceeding certain value thresholds.
It is worth stressing that the new rules will take the form of an EU regulation, not a directive. This means they will apply directly in all EU countries, without any need for implementation into national law. For businesses and consumers the result is the same: from mid-July 2027, purchases above the set threshold will look completely different from today.
PESEL, NIP and IBAN - what details will you have to provide?
The AML regulation sets a threshold of €10,000 (currently around PLN 43,000). For transactions above this amount, sellers will be required to verify the buyer's identity in detail. In practice, this means having to provide several key identification details.
The list of required information includes in particular:
- PESEL number - the basic identifier of an individual in Poland
- NIP number (Polish tax identification number) - particularly relevant for business transactions
- IBAN number - that is, the number of the bank account from which the payment is made
Importantly, the form of payment will not matter. Identical rules will apply to both cash and electronic payments, including bank transfers and card payments. Even if a customer pays by transfer from their own account, the seller will still have to establish the actual purchaser and confirm that the transaction is not being made on someone else's behalf. This is a significant change in approach - the mere fact that the customer has been identified by a bank does not release the seller from the obligation to carry out verification.
Who will the new AML rules apply to?
The scope of the regulation in terms of who is covered is much broader than it might seem at first glance. The new identification rules go far beyond traditional financial and banking institutions. The list of sectors subject to the customer verification obligation is extensive and includes entities that until now have not had to apply such rigorous procedures.
Sectors subject to the verification obligation
The main categories of entities required to apply the new rules include:
- Car dealers - when selling vehicles worth more than the threshold
- Estate agents - when acting as intermediaries in property market transactions
- Art galleries and auction houses - as well as independent art dealers
- Sports clubs - in the context of transfers and high-value transactions
- Law firms - when handling certain types of transactions
- Lending companies - operating outside the banking system
- Crowdfunding platforms - as entities intermediating the flow of funds
- Crypto-asset businesses - exchanges, trading platforms and service providers
It is worth noting an important exclusion: the restrictions will not apply to transactions between individuals. This means that a private sale of a car "hand to hand" between two private persons will not be subject to the new identification requirements. The obligation applies only where one of the parties to the transaction is a professional entity.
A lower threshold for cash payments - €3,000
The AML regulation introduces additional, stricter rules for cash transactions. For cash payments, businesses will be able to apply simplified verification rules from an amount exceeding three thousand euro. This is a significantly lower threshold than the standard €10,000 that applies to non-cash payments.
"Simplified verification rules" do not, however, mean no verification - on the contrary, even for smaller amounts the seller may be required to collect basic information about the customer. The exact scope of the information requested will depend on the risk assessment and the rules in force in the given country. In practice, this means that in some situations providing personal data may be necessary even when making purchases of relatively low value.
Such a strict approach to cash stems from the fact that cash payments are traditionally regarded as more vulnerable to use in money laundering. The lack of an electronic trail makes it harder for law enforcement authorities to reconstruct the flow of funds, which is why the EU legislator decided to differentiate thresholds depending on the form of payment.
Standardisation of AML rules across the European Union
One of the most important aspects of the new regulation is the elimination of differences between the national laws of individual member states. Until now, each EU country has implemented anti-money laundering directives in a slightly different way, which has led to legal loopholes. Criminals could choose jurisdictions with more lenient verification requirements, effectively bypassing controls.
Standardising the procedures is intended to bring several key benefits. First, uniform rules will make regulatory arbitrage more difficult - that is, the deliberate exploitation of differences between legal systems. Second, uniform standards will facilitate cross-border cooperation between financial supervisory authorities. Third, companies operating in several EU countries will be able to apply a single set of procedures instead of adapting to many different national regulations.
For businesses operating in sectors covered by the new rules - including companies in the crypto-asset sector - it will be crucial to prepare internal procedures properly before the regulation enters into force. It is worth remembering that reporting profits from cryptocurrencies already requires knowledge of the rules in force in different jurisdictions, and the new AML regulations will add further complexity to this area.
How to prepare your business for the new AML requirements? Take advantage of a free consultation
The AML regulation, which is due to enter into force in mid-July 2027, will affect a wide range of businesses - from car dealers and art galleries to crypto-asset companies and law firms. The new verification obligations will require the implementation of appropriate procedures, staff training and adapting IT systems to collect and store customer data.
If you run a business in a sector covered by the new regulations - in particular if your company operates in the area of cryptocurrencies, international trade or handles high-value transactions - it is worth consulting specialists now to assess the impact of the changes on your business. The Global Tax Partners team offers comprehensive support with regulatory compliance, cryptocurrency tax reporting and international structures.
Book a free consultation - call +48 505 684 412 or get in touch via the website globaltax.partners. We will help you prepare your business for the upcoming changes and plan your actions in line with the new rules.
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