Published 7 October 2026

Politically exposed persons in EU law: the common rules, and the lists each country keeps

A head of government, a central bank board member, the director of an international organisation. EU law decides what makes someone a politically exposed person and what you owe them in due diligence; each Member State decides which exact posts are on its list. Here is the common rulebook, as it applies today and as the AMLR rewrites it from 10 July 2027.

This guide covers European Union law. What each Member State sets for itself (the authority that supervises you, the financial intelligence unit that receives your reports, how you file them) is set out country by country: Ireland, Malta and every other Member State.

Under EU law, a politically exposed person (PEP) is a natural person who is or has been entrusted with prominent public functions. Today the definition sits in Article 3(9) of Directive (EU) 2015/849; from 10 July 2027 it moves to Article 2(1)(34) of Regulation (EU) 2024/1624, the AMLR. Both texts draw the same line at the bottom: middle-ranking or more junior officials are never covered (Directive, Article 3(9); AMLR, Article 2(2)).

Two texts, one switchover date

Until 10 July 2027, the EU rules on PEPs live in a directive, and a directive is addressed to the Member States rather than to firms (Directive, Article 69). Each Member State had to transpose the original text into its own law by 26 June 2017 (Article 67), and each may go further than the Directive does (Article 5). So what binds a firm today, wherever it is in the Union, is the national law transposing Directive (EU) 2015/849, as amended in 2018 by Directive (EU) 2018/843.

On 10 July 2027 the rules change shape: the AMLR, applicable from that date, is directly applicable in every Member State, with no transposition (Article 90). The same day, Directive (EU) 2015/849 is repealed (Directive (EU) 2024/1640, Article 77). The Regulation explains the switch itself: applied through national transpositions, the Directive's rules had been implemented in a fragmented way along national lines (recital 2).

Who is on the list

The EU list is short and specific. Under the Directive it covers:

• heads of State, heads of government, ministers and deputy or assistant ministers;
• members of parliament or of similar legislative bodies;
• members of the governing bodies of political parties;
• members of supreme courts, of constitutional courts and of other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances;
• members of courts of auditors and of the boards of central banks;
• ambassadors, chargés d'affaires and high-ranking officers in the armed forces;
• members of the administrative, management or supervisory bodies of State-owned enterprises;
• directors, deputy directors and members of the board, or equivalent, of an international organisation (Article 3(9)).

The AMLR keeps that frame and adjusts it in four places. Party officials count only where the party holds seats in national executive or legislative bodies, or in regional or local ones representing at least 50,000 inhabitants. Heads of regional and local authorities with at least 50,000 inhabitants join the list. State-owned enterprises now include medium-sized and large enterprises controlled by regional or local authorities. And the text names equivalent functions at Union level and in third countries, along with representatives of international organisations to a Member State or to the Union (Article 2(1)(34)). Each Member State can still add prominent public functions of its own (point (34)(a)(ix)).

Nor is 50,000 the last word: Member States may set a lower threshold on the basis of risk, and should tell the Commission when they do (recital 91).

Relatives and close associates

The measures do not stop at the PEP. They also apply to the PEP's family members and to persons known to be close associates (Directive, Article 23; AMLR, Article 46).

Under the Directive, family means a spouse or a person considered equivalent to a spouse, children and their spouses or equivalent partners, and parents (Article 3(10)). The AMLR adds siblings, but only around the top of the list: heads of State or government, ministers, deputy or assistant ministers, and equivalent functions at Union level or in a third country (Article 2(1)(35)(d)). Member States may draw the sibling circle wider, and should tell the Commission if they do (recital 97).

Close associates are defined in the same terms in both texts. First, anyone known to share beneficial ownership of a legal entity or legal arrangement with a PEP, or to have any other close business relations with one. Second, anyone who is the sole beneficial owner of an entity or arrangement known to have been set up for the de facto benefit of a PEP (Directive, Article 3(11); AMLR, Article 2(1)(36)). AMLA has until 10 July 2027 to issue guidelines on how to identify close associates (AMLR, Article 42(2)).

What enhanced due diligence means here

It starts with a question you put to every customer. The Directive requires appropriate risk management systems, including risk-based procedures, to determine whether the customer or the customer's beneficial owner is a PEP (Article 20(a)). The AMLR makes that check part of standard customer due diligence and widens it to family members, close associates and anyone on whose behalf or for whose benefit a transaction is carried out (Article 20(1)(g)).

If the answer is yes, both texts add the same three measures on top of standard due diligence (Directive, Article 20(b); AMLR, Article 42(1)):

• senior management approval to establish or continue the business relationship;
• adequate measures to establish the source of wealth and the source of funds involved;
• enhanced, ongoing monitoring of the relationship.

Two details shift in 2027. The Directive applies these measures to business relationships; the AMLR extends them to occasional transactions. And "senior management" is drawn differently. For the Directive, it is an officer or employee who knows the firm's risk exposure well enough, and is senior enough, to take decisions on it, without necessarily sitting on the board (Article 3(12)). For the AMLR, it means the members of the management body in its management function, as well as those officers and employees (Article 2(1)(40)).

Life and other investment-related insurance has a rule of its own. Firms take reasonable measures to determine whether the beneficiary, or the beneficiary's beneficial owner, is a PEP, no later than the payout or the assignment of the policy. Where the risk is higher, senior management is informed before the payout and the whole relationship with the policyholder comes under enhanced scrutiny (Directive, Article 21; AMLR, Article 44).

After leaving office: twelve months at least

A PEP who leaves office does not stop being a risk overnight. The Directive requires firms to take that continuing risk into account for at least 12 months, and for as long as the person still poses a risk specific to PEPs (Article 22). The AMLR keeps the minimum and spells out the tools: one or more of the enhanced measures listed in Article 34(4), until the risk is gone and in any case for at least 12 months after the function ended (Article 45(1) and (2)). The same applies when a relationship only begins after the person has left office (Article 45(3)).

What stays national

The definition is European; the exact list of posts is not. Each Member State issues and keeps up to date a list of the functions that count as prominent public functions under its own law, and asks the international organisations on its territory to do the same. The Commission draws up the list for Union institutions and bodies and assembles everything into a single list (Directive, Article 20a, inserted by Directive (EU) 2018/843; AMLR, Article 43). On 10 November 2023 the Official Journal of the European Union published a document bringing together the lists of all 27 Member States and of the Union institutions and bodies (C/2023/724). Treat it as a starting point, and check it against the list your country keeps today.

Several other things are settled nationally as well: the law transposing the Directive, which may be stricter than the Directive itself (Article 5); from 2027, the thresholds and circles the AMLR lets Member States lower or widen (recitals 91, 92 and 97); the authority that supervises you; and the financial intelligence unit that receives your reports. Our Europe page lists the supervisor and the FIU for each Member State. For the list of posts, go to your country's own publication.

A PEP is not a suspect

The AMLR puts it plainly. The PEP rules are preventive, not criminal, and should not be read as implying that PEPs, their family members or their close associates are involved in crime. Refusing a business relationship simply because someone is a PEP, a family member or a close associate is "contrary to the letter and spirit" of the Regulation (recital 98).

The Directive already frames the relationship without forbidding it: it asks for approval "for establishing or continuing" business relationships with PEPs (Article 20(b)(i)). A file holds up because of what it records, not because the door was closed: the question asked, the answer given, the source of funds established, the decision taken at the right level.

What you can do now

• Write down in your procedures how the PEP question is asked, by whom, and where the answer is kept.
• Get your country's list of prominent public functions, and look beyond national posts: the definition also reaches international organisations and, under the AMLR, Union-level functions and their equivalents in third countries.
• Record the date a former PEP left office, and plan a review at 12 months at the earliest rather than an automatic switch-off.
• Name the person in your firm who acts as senior management when a PEP relationship needs approval.
• Get ready for 2027: siblings of the most senior office-holders, heads of local authorities with 50,000 inhabitants or more, occasional transactions. Our guides to the AMLR and to AMLA, which will issue the close-associate guidelines, take it from there.

Vigilae, AML compliance software, prepares the due-diligence file for a PEP case as for any other; you decide whether to go ahead, and you remain solely responsible for your reports. See how it works.

Informative article, current as of 7 October 2026, not constituting legal advice. The articles cited were checked against the texts published in the Official Journal of the European Union; your country's list of functions and the national law transposing the Directive should be checked with your supervisor.

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