EBA ¦ The AML/CFT Colleges Framework is Maturing, the EBA finds

EBA’s final AML/CFT colleges report: progress stabilised but two core gaps persist

The European Banking Authority’s Report on the Functioning of AML/CFT Colleges in 2024–25 is the final assessment the EBA will publish before responsibility for monitoring colleges transfers to the European Anti-Money Laundering Authority (AMLA) on 1 January 2026. Covering 1 January 2024 to 31 May 2025, the report assesses how the permanent supervisory structures for cross-border firms are working, summarises EBA monitoring activity, and tracks progress against six action points the EBA has promoted since colleges began in 2020. The findings are pragmatic: the colleges framework is now established and operational across the EU, but meaningful improvements are still required if colleges are to deliver coordinated, risk-focused supervision of cross-border financial crime risks.

Colleges are established, stable and used — but with limits

The EBA found 258 AML/CFT colleges in operation as of 31 May 2025 (slightly fewer than the 264 counted at the end of 2023). The largest share were linked to credit institutions; many others related to investment firms, payment institutions and collective investment undertakings. Colleges range in size from very small (some newly created groups with incomplete membership) to 32 members; most have between three and five permanent members.

Participation by domestic authorities is steady. Financial intelligence units took part in about 58% of colleges, and prudential supervisors in about 71%, unchanged from 2023. Onboarding of third-country observers rose modestly (57 colleges reported at least one third-country observer, up from 41), but the absolute number of outside observers remains limited. The main practical reason is the need for equivalence assessments of confidentiality regimes; the EBA has progressed a few such assessments during the reporting period but many potential third-country participants are not yet covered.

Routine functioning and information exchange

Most colleges are taking a pragmatic approach to organisation. About 45% meet once per year; roughly equal shares meet every two or three years or operate mainly through written exchange. Around 58% invite the firm to attend as an ‘invited participant’ for parts of meetings. Lead supervisors generally perform well at organising agendas, circulating materials and steering discussions. Where lead supervisors use structured templates and require targeted firm presentations, the quality of discussion improves and members arrive better prepared.

Bastian Schwind-Wagner_Follow "The EBA’s 2024–25 review finds AML/CFT colleges well established and operational across the EU, but highlights persistent gaps in applying a risk-based meeting model and in driving coordinated, cross-border remediation. Addressing those two priorities is essential as AMLA assumes monitoring responsibilities to ensure colleges become instruments for consistent, risk-focused action against ML/TF."

Active monitoring — targeted scrutiny of selected colleges

EBA staff actively monitored a subset of colleges (nine colleges participated in EBA-attended meetings between January 2024 and May 2025). In those colleges the EBA observed clear improvements: agendas sent in advance, focused presentations, proactive chairing and better use of pre-circulated templates and spreadsheets. In some cases members agreed limited coordinated responses — for example sharing supervisory findings to enable a lead supervisor to consolidate group-level conclusions.

Two persistent weaknesses undermine effectiveness

Despite the operational stability and the pockets of good practice, the EBA concluded that competent authorities made only limited progress on two priority items identified in prior reports, and those shortfalls materially constrain colleges’ impact.

First, the risk-based organisation of colleges remains only partially implemented. Although some lead supervisors use the firm’s ML/TF risk profile to set meeting frequency (for example, higher frequency for higher risk), many colleges still default to annual meetings regardless of risk or group characteristics. That creates two problems: attention and resources are spread too thin across too many meetings, and lead supervisors struggle to prioritise the most strategic colleges. Over-meeting less strategic groups makes it harder for supervisors to allocate experienced staff and maintain sustained engagement where it matters most.

Second, colleges are not consistently used to identify and act on common or cross-border issues. While members do exchange meaningful information, few colleges push those exchanges toward a systematic assessment of cross-cutting risks and a decision on whether coordinated remedies are needed. Lead supervisors rarely schedule explicit agenda time to synthesise inputs, identify commonalities, or drive a decision about a joint approach. In many meetings members do not summarise findings, nor do they follow up with proposals for aligned remediation. The result: similar weaknesses and supervisory findings across jurisdictions are often handled in isolation, risking inconsistent remedies and an incomplete group-level response.

Other action areas — cooperation and supervisory convergence

The EBA graded progress across its six action points. Structural elements and meeting quality were largely implemented: most colleges exist, cooperation agreements are mostly in place, and meeting processes have improved. Ongoing cooperation between members also shows positive signs: some ad hoc meetings take place when significant AML/CFT issues arise and information is shared in a timely manner. However, steps to identify areas where common approaches or joint action are needed are only partially implemented, and enhanced supervisory convergence — sharing methods and approaches across supervisors to harmonise practice — remains largely unaddressed.

Practical consequences and supervisory risk

The combined effect of an inconsistent risk-based approach and weak pursuit of common solutions is a supervisory framework that can exchange information but is not yet optimised for preventing, detecting and remediating cross-border ML/TF risks. Where supervisors do not align remediation or take coordinated action, firms that operate across multiple Member States may receive fragmented supervision, leaving residual vulnerabilities unaddressed or remedied inconsistently.

Recommendations and priorities for AMLA and national supervisors

As AMLA assumes monitoring responsibilities in 2026, the EBA’s final observations point clearly to two priorities:

1. Recalibrate meeting frequency and format to risk. Lead supervisors must tailor the cadence and intensity of colleges to a firm’s ML/TF risk profile and cross-border footprint. Practical steps include adopting formal criteria to link meeting frequency to risk, consolidating low-priority colleges into lighter-touch written exchanges, and focusing in-person meetings on the highest-risk and most complex cross-border groups.
2. Make colleges vehicles for joint problem solving. Meeting agendas should explicitly require synthesis of member inputs, identification of cross-cutting risks and a deliberation on coordinated remedies. Lead supervisors should use pre-meeting templates to collect comparable inputs, summarise cross-jurisdiction patterns in advance, and propose concrete joint or aligned actions where appropriate. Where remediation measures are agreed locally, colleges should compare outcomes to detect inconsistency and step in when alignment is needed.

Other supporting measures that AMLA and national authorities should prioritise include accelerating equivalence assessments to enable third-country observers where useful, promoting the use of standardised exchange templates and shared summaries to improve comparability, and dedicating experienced staff to strategic colleges to preserve institutional memory and follow-through.

Conclusion — a stable tool with untapped potential

The EBA’s 2024–25 review shows AML/CFT colleges are now an established component of EU AML/CFT supervision: they meet, they exchange meaningful information, and lead supervisors are generally capable chairs. Yet the system’s full supervisory value will only be realised if colleges become more targeted by risk and more deliberate about identifying and pursuing common, cross-border solutions. With AMLA taking over coordination next year, the window is open to convert good practice into consistent practice so colleges become not just channels for information, but instruments for coordinated action against cross-border financial crime risks.

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• EBA ¦ The AML/CFT colleges framework is maturing, the EBA finds ¦ Link