AML REQ for Investment Firms
The AML REQ is the Central Bank of Irelandâs annual data return on your firmâs money laundering and terrorist financing risk. Customers, products, jurisdictions, controls.
The return must be submitted through the Central Bank Portal using the prescribed XML schema. Only XML submissions are accepted.
Why it matters:
Statutory: Mandatory under your AML/CFT obligations.- Supervisory: The data directly shapes whether the CBI lines you up for a deep-dive inspection.
- Strategic: Feeds into the incoming EU AMLA framework
- Visible: Quality and completeness signal the maturity of your AML programme.
Whatâs the scope?
Reporting dates
Reference date: 31 December of the preceding calendar year
First submission deadline: 30 June 2026
Reporting frequency
Annual reporting
File format
XML format only, aligned with the prescribed XSD schema, and submitted via the Central Bank Portal. Excel files are provided for reference purposes only and cannot be submitted.
Whatâs actually changing?
The CBI is moving from a one-size-fits-all REQ which was in Excel format, to a sector-specific one in machine-readable XML format. Hereâs the difference:
Before
- One generic return for every firm
- Light on detail, broad on categories
- Excel-friendly
- Manageable in-house
After
- Sector-specific returns
- Granular AML data, hundreds of new fields
- XML only, strict schema, every field mandatory
- First submission: 4-8 weeks of effort
Key data areas
The REQ captures information relating to:
- Legal structure and business model
- Customer segments and risk ratings
- Transaction volumes and values
- High-risk customers and sectors
- International presence
- Funding methods and intermediaries
- Remote onboarding
- Crypto-asset activity
- BWRA and risk appetite
- AML/CFT policies and procedures
- Transaction monitoring and STR controls
- Governance, audit and training arrangements
Reporting considerations to keep in mind
- All data points are mandatory, including non-applicable fields
- Non-applicable fields must use prescribed default values (e.g. 0, N/A, 2000-01-01)
- XML submissions must follow strict schema, table structure and table ordering requirements
- Files must be validated before submission
- Firms must complete both âFinaliseâ and âSign-Offâ steps within the portal
- All values should be reported in EUR
So, what do you need to do?
There are no shortcuts, here is what the CBI requires end-to-end.
Download and review the REQ guidance pack
Download and review the sector-specific REQ pack, including the guidance notes, XML schema and reference files, to understand the reporting requirements in full.
Prepare and map your reporting data
Align internal AML/CFT, customer, product and transaction data to the required REQ fields. Every field is mandatory & has a strict format.
Validate against the XSD schema
Validate the XML file against the Central Bankâs schema and formatting rules to identify structural or mandatory field errors before submission. Excel wonât fly. XML schema only.
Obtain internal sign-off
Complete internal review and approval processes before submission (typically MLRO and board-level).
Upload the return via the Central Bank Portal before 30 June 2026
Submit the validated XML return through the Central Bank Portal and complete the required finalisation and sign-off steps.
Maintain an audit trail
Retain supporting documentation, validation records and reporting evidence to support audit and regulatory review requirements. The CBI will ask.