New EU Identification Rules for High-Value Purchases Starting in 2027

Starting July 10, 2027, the European Union’s AMLR regulation will require vendors to perform customer due diligence for high-value transactions, potentially including the collection of national identification numbers like PESEL.

New Compliance Requirements for Retailers

The new European Union regulations are not intended for daily grocery shopping or consumer electronics. Instead, the rules focus on high-value transactions and industries that the European Union identifies as being more vulnerable to money laundering.

Starting July 10, 2027, when the EU’s Anti-Money Laundering Regulation (AMLR) takes effect, the list of entities required to verify customer identities will expand significantly. Businesses will now need to implement verification procedures previously reserved for the banking sector.

Thresholds for Customer Identification

If a single transaction or a series of linked transactions reaches the value of 10,000 euros, the vendor must conduct a Customer Due Diligence procedure. This involves verifying the identity of the customer and collecting the data required by AML laws.

In Poland, identifying a natural person may involve collecting the PESEL number alongside data from an official identity document. While the regulation does not explicitly mandate the PESEL number across the entire EU, it requires businesses to collect enough data to unambiguously identify the customer.

Electronic Payments and Cash Limits

The new regulations eliminate the assumption that a bank transfer automatically validates the legality of a transaction. Once a transaction exceeds the statutory threshold, the vendor must perform verification regardless of whether the customer pays by cash, card, or bank transfer.

Specific rules also apply to cash transactions. For occasional cash payments of at least 3,000 euros, vendors must verify the customer even if the 10,000-euro threshold is not met. Additionally, the regulation establishes a general EU-wide limit of 10,000 euros for cash payments to businesses, though member states retain the right to impose stricter national limits.

Harmonizing Anti-Money Laundering Efforts

The European Commission has long argued that criminals exploit disparities between national anti-money laundering systems. The new AML package aims to harmonize these rules across the European Union, ensuring that businesses operate under identical regulations and making it easier for law enforcement to track the movement of illicit funds.