AML amendment: goAML registration by 30 November 2026 and stricter beneficial owner verification

The anti-money laundering amendment, Act No. 73/2026 Z. z., effective from 1 June 2026, introduced an obligation that is easy to miss: registration of obliged entities in the Financial Intelligence Unit’s system. The law also imposes strict beneficial owner verification requirements, and the amendment opens beneficial ownership data to persons demonstrating a legitimate interest. Autumn is the last opportunity to complete everything without a rush.

Who is covered?

Section 5 of Act No. 297/2008 Z. z. defines obliged entities. Actual activity matters, not the formal business objects entered in a register. Besides banks and financial institutions, these include estate agents, accountants, auditors, tax advisers, asset and company service providers, insolvency administrators, enforcement officers for specified activities, and lawyers and notaries providing legal services connected with money movements, from property and business purchases to company formation and management. Any business carrying out a cash transaction worth at least EUR 10,000 also becomes an obliged entity (§ 5(3)).

goAML registration: two deadlines

The Financial Intelligence Unit receives unusual transaction reports through goAML. Under § 21(2), an obliged entity must register within 30 days of acquiring that status. A special transitional deadline applies to entities already obliged before the amendment:

Unofficial English translation:

An obliged entity must register by 30 November 2026 in the Financial Intelligence Unit’s system under § 21(2), as effective from 1 June 2026. — § 36d(1) of Act No. 297/2008 Z. z.

Registration is more than a box to tick. Without it, the entity cannot fulfil its reporting obligation when an unusual transaction actually arises. Breaches of the Act are administrative offences punishable by Financial Intelligence Unit fines (§ 33).

Beneficial owners: a register extract is not enough

Basic due diligence includes identifying the beneficial owner, generally an individual holding at least 25%, and verifying that identification. The law is explicit: information must come from reliable sources using a risk-based approach, and the obliged entity must not rely exclusively on data from the register of legal entities (§ 10(1)(b)). Downloading and filing an extract is therefore not verification. The client’s ownership and management structure must be examined: formation documents, shareholder lists and, for more complex structures, foreign registers. See who is a beneficial owner? for how the person is identified.

The audit trail is equally important. On inspection, the obliged entity must demonstrate that the extent of due diligence matched the risk (§ 10(4)) and retain records of the client assessment, analyses and individual actions for five years after the business relationship ends (§ 19(2)). A general policy without client-specific records does not demonstrate adequate diligence.

What to do now

First, register in goAML before the transitional deadline. Second, audit the internal AML programme. The law requires updates, including following AML legislative amendments, approved by the statutory body (§ 20). A programme written before 2026 cannot reflect the amendment. Third, establish records for each client covering verification sources, discrepancies and decisions, and train client-facing staff.

Our guide to AML obligations for estate agencies summarises their responsibilities. Beneficial owners during lawyer authorisation explains verification when a lawyer authorises a contract.

We help establish AML arrangements, from the internal programme and registration to checking an individual client, through AML for businesses. Our external legal department can monitor ongoing obligations, while s.r.o. corporate documentation keeps structural records in order.