Brussels, 29 April 2026
Financial Stability, Financial Services and Capital Markets Union
Reasoned opinions
Commission calls on Spain and Poland to transpose the amendments to the 4th Anti-Money Laundering Directive and complete the implementation of other measures introduced by the Transfer of Funds Regulation
Today, the European Commission decided to send a reasoned opinion to
Spain (INFR(2025)2079) and
Poland (INFR(2025)2081)
for failing to transpose the amendments to the 4th Anti-Money Laundering Directive (AMLD) (Directive (EU) 2015/849) introduced by the Transfer of Funds Regulation (Regulation (EU) 2023/1113) and for failing to notify to the Commission the rules on administrative penalties and other measures applicable to infringements of the Regulation.
The Transfer of Funds Regulation (TFR) lays down rules on the information on payers and payees accompanying transfers of funds in any currency, and on originators and beneficiaries accompanying transfers of crypto-assets, for the purposes of preventing, detecting and investigating money laundering and terrorist financing. It replaces and broadens the scope of the former Regulation on information accompanying transfers of funds (Regulation (EU) 2015/847) and amends the 4th Anti-Money Laundering Directive in order to introduce new requirements on information accompanying transfers of crypto-assets.
In addition, the TFR requires that Member States adapt their national legal frameworks. These provisions were already contained in the previous version of the TFR (Regulation (EU) 2015/847) but require additional measures from Member States to ensure they also apply administrative sanctions and measures, in particular for the breaches related to crypto-assets services providers.
The two Member States have failed to notify transposition of the amendments made to the 4th AMLD and have not completed the implementation of the Regulation on administrative penalties and other measures by the 30 December 2024 deadline. The TFR is a key European legislative act designed to combat money laundering and terrorist financing by ensuring the traceability of financial transfers. Failing to implement it has legal, financial, and operational risks for institutions and individuals and, especially, for all Crypto-Asset Service Providers operating in the EU. Therefore, the Commission has decided to issue reasoned opinions to the two Member States concerned, which now have two months to reply and take the necessary measures. Otherwise, the Commission may decide to refer the cases to the Court of Justice of the European Union.
Commission calls on Spain, the Netherlands, Portugal and Sweden to fully transpose the European Single Access Point (ESAP) Omnibus Directive to ensure investors’ access to corporate public information
Today, the European Commission decided to send a reasoned opinion to
Spain (INFR(2025)0269),
the Netherlands (INFR(2025)0281),
Portugal (INFR(2025)0285) and
Sweden (INFR(2025)0288)
for failing to fully transpose the European Single Access Point (ESAP) Omnibus Directive (Directive EU 2023/2864) in relation to the changes introduced in the Transparency Directive (Directive 2004/109/EC) following a letter of formal notice sent in July 2025.
The ESAP Omnibus Directive is part of the ESAP legislative package that facilitates the creation of a centralised mechanism offering easily accessible, comparable and usable public information to investors and other stakeholders. Easy and structured access to information by market participants will contribute to the integration of EU capital markets, in line with the Savings and Investments Union objectives. This will facilitate the financing of EU companies, thus driving growth and job creation in the EU.
The legislative package foresees three phases of ESAP development. The first phase will begin in July 2026, when disclosures required under the Transparency Directive, the Prospectus Regulation and the Short Selling Regulation will be submitted to national competent authorities so they can be made available on ESAP. For that first step, Member States had to transpose the changes introduced in the Transparency Directive by 10 July 2025, as indicated in the letter of formal notice sent in July 2025. Therefore, the Commission has decided to issue reasoned opinions to the four remaining Member States who had not transposed the changes, which now have two months to reply and take the necessary measures. Otherwise, the Commission may decide to refer the cases to the Court of Justice of the European Union, with requests to impose financial sanctions.
Source – EU Commission