The 2024 package is usually described as a single deadline. It is not. The substantive rules move into Regulation (EU) 2024/1624, which applies directly from 10 July 2027, but the supervisory directive alongside it transposes in tranches that started earlier, and two significant pieces do not fall due until 10 July 2029.
That matters for planning, because a programme built around one cutover date will be late for the tranches already behind it and early for the carve-outs at the end.
What actually changes on the substance
The largest shift is not any single obligation. It is that a directly applicable regulation replaces twenty-seven national transpositions. Where a firm's customer due diligence standard was effectively set by one member state's reading of the fourth or fifth directive, the reference point becomes the regulation's own text.
For a group operating across several member states, this cuts both ways. Divergence that required maintaining different standards per jurisdiction disappears. Divergence that a firm had relied on, because one transposition was more permissive than its neighbours, disappears with it.
The part most programmes underestimate
The new standard is not limited to customers onboarded after the date. It applies to the book you already have, which makes remediation the largest single workstream and the one with no deadline of its own to anchor it.
That work is a screening and evidence exercise rather than a policy exercise: establishing which existing customers were assessed against a standard that no longer applies, re-running due diligence where the gap is material, and recording the basis for each decision.
A different supervisor, not just different rules
From 2028, AMLA directly supervises selected cross-border institutions from its seat in Frankfurt am Main. For firms in that population, the change is not only what the rules say but who tests them, in what format, and against what expectations.
The first readiness question is therefore whether you expect to be in direct scope, because the answer changes who you are preparing for. Firms outside it continue under national supervisors and should plan against those supervisors' timetables.
What good evidence looks like
Readiness programmes are assessed retrospectively, by someone who was not present for any of the decisions. The useful test is whether a reviewer arriving in 2028 could reconstruct what you did and why, from records rather than recollection.
That favours decisions recorded at the point they were taken, tied to the obligation they respond to, over a summary assembled afterwards from memory.
For the instruments themselves and how the "6AMLD" label came to cover two different directives, see the 6AMLD explainer. For the transfer of funds regime that already applies, see the EU Travel Rule. For the screening components, see PEP and sanctions screening and enhanced due diligence.