AML REQ for Life Insurance Institutions
The Risk Evaluation Questionnaire (REQ) for Life Insurance is an annual AML/CFT/FS return issued by the Central Bank of Ireland.
The REQ collects information on:
A firm’s inherent ML/TF/FS risk exposure- How the firm assesses ML, TF and financial sanctions risk within its business model
- The AML/CFT/FS framework, governance and controls in place
- Customer, product, transaction and geographic risk data
The return must be submitted through the Central Bank Portal in XML format using the prescribed XSD schema. Excel files are provided for reference only and cannot be submitted.
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
Steps to submission
A high-level overview of the key stages involved in preparing, validating and submitting the Life Insurance AML REQ return to the Central Bank of Ireland.
Determine reporting scope and legal structure
Confirm whether the return should cover Irish institution data only or whether specific EEA aggregated reporting applies.
Gather required AML/CFT, customer and policy data
Collect the required data across policyholders, products, transactions, geographies, intermediaries, onboarding channels and AML/CFT controls.
Map data to the required XML schema and REF fields
Align each data point to the prescribed XML taxonomy, including REF identifiers, enumerations, table structures and field formats.
Generate and validate the XML file
Create the XML return in line with the XSD schema and validate it against mandatory fields, formatting rules and table ordering requirements.
Upload the return via the Central Bank Portal
Submit the validated XML file through the Central Bank Portal and resolve any validation issues raised during upload.
Finalise and sign off the submission
Complete the Portal “Finalise” and “Sign-Off” steps to ensure the REQ is successfully completed and transmitted.