AML REQ for Life Insurance Institutions
The AML REQ is the Central Bank of Ireland’s annual data return on your firm’s 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.
What’s the scope?
Entities in scope
The AML REQ applies to Life Insurance institutions regulated by the CBI. Each regulated institution must submit its own REQ using the sector-specific XSD schema.
Group & branch reporting
Where the institution is a Parent_of_group within the EEA or a Stand_alone_entity, Sections 8.2.2 and 8.4.16 must be reported on an aggregated basis for EEA entities. The remaining sections are reported for the Irish institution only; other legal structures report Irish institution data only.
Activity covered
The REQ captures information across life insurance products, customer segments, high-risk sectors, intermediaries, remote onboarding, cash transactions, PEP exposure, geography of funds flow, transaction monitoring and AML/CFT controls.
Reporting dates
Standard reference date: 31 December of the preceding calendar year
First submission deadline: 11 September 2026
Reporting frequency
Annual reporting
File format
XML format only, aligned with the prescribed XSD schema and required XML wrapper. The XML file must be validated before upload to the Central Bank Portal.
Key data areas
The Life Insurance REQ requires information across:
- Legal structure and EEA international presence
- Statement of compliance
- Customer segments and high-risk customer activity
- High-risk legal entity customer sectors
- Protection policies and investment policies
- Pension and non-pension investment contracts
- Highly Personalised Portfolio Bonds
- Policy surrender and reassignment activity
- Cash inwards and cash outwards transactions
- Intermediaries and distribution channels
- Remote onboarding
- BWRA, risk appetite and AML/CFT controls
- Policies, procedures, governance, audit and training
- Customer due diligence and periodic review backlogs
- Sanctions screening and transaction monitoring
- Physical presence, residence and establishment
- Politically exposed persons
- Geography of funds flow
Reporting considerations to keep in mind
- All questions are mandatory, even where a data point is not applicable
- Non-applicable fields must use the prescribed default values, such as 0, N/A, 2000-01-01 or the required default enumeration
- For this REQ, “customer” refers to the policyholder
- All values should be reported in full euro unit value
- Customer risk ratings may be based on the rating as at the reference date, even if the rating changed during the year
- XML submissions must follow the required table structures and strict table ordering
- Incorrect XML structure or table order may result in rejection
- The file name must follow the required format: CCCCCC_YYYYMMDD_A05.xml
- Firms must complete both the “Finalise” and “Sign-Off” steps in the Portal
- Material issues should still be raised through normal supervisory channels, not solely through the REQ
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 Bank’s schema and formatting rules to identify structural or mandatory field errors before submission. Excel won’t 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 11 September 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.