On August 14, 2026, Norway's Advokattilsynet (the supervisory authority for advocates) flagged that the EU Anti-Money Laundering Authority (AMLA) has opened a public consultation on draft Regulatory Technical Standards (RTS) for assessing the inherent and residual money-laundering and terrorist-financing risk of obliged entities in the non-financial sector. The RTS is drafted under Article 40(2) of Directive (EU) 2024/1640 (AMLD6) on risk-based supervision and is already mirrored in Norway's draft new anti-money laundering act at proposed section 8-4. Consultation closes on September 27, 2026.
The draft does not invent new gatekeeper duties for lawyers today. It harmonises how supervisors, including Advokattilsynet once the EEA AML package is incorporated and transposed, must classify firm-level ML/TF risk and which data they will systematically collect from obliged entities, including law firms. Norwegian AML compliance leads and partners should treat this as the template for future supervisory questionnaires and risk ratings, not as optional EU soft law.
What exactly did AMLA put on the table?
AMLA's consultation covers draft RTS on the assessment of the inherent and residual risk profile of obliged entities in the non-financial sector, including lawyers and other gatekeepers. According to Advokattilsynet's August 14, 2026 notice, the standards aim to align how supervisors evaluate and classify ML/TF risk across that sector and set expectations on the information supervisors must obtain from obliged entities as the basis for those assessments.
The legal hook is AMLD6 Article 40(2) on risk-based supervision. Advokattilsynet notes that the same provision is proposed for inclusion in Norway's draft new anti-money laundering law at section 8-4, so the RTS will shape Norwegian supervisory practice once the EEA Joint Committee incorporates the EU AML package and the Storting completes transposition. Full consultation materials are on AMLA's consultation page; AMLA also summarised the initiative in its press release on harmonised risk assessments.
Who is impacted in Norway, and when does it bite?
Primary audience: Norwegian law firms and advocates already treated as obliged entities under the Hvitvaskingsloven, plus compliance officers preparing for AMLD6-aligned duties. Secondary audience: other non-financial obliged entities Advokattilsynet's notice groups with lawyers under the same RTS perimeter.
There is no new firm-level filing obligation on September 27, 2026. That date is the consultation deadline. Binding effect arrives only after AMLA finalises the RTS and after EEA incorporation plus Norwegian transposition of AMLD6 (EU transposition deadline July 10, 2027; Norway follows the EEA path, so timing can lag the EU calendar). Firms that wait until the Norwegian lov is promulgated will discover that supervisors already designed the risk grid and data asks in this RTS.
| Milestone | Date / status | What it means for law firms |
|---|---|---|
| Advokattilsynet alert | August 14, 2026 | National supervisor signals RTS relevance for advocates |
| AMLA consultation closes | September 27, 2026 | Last day to submit comments on the draft RTS |
| AMLD6 EU transposition deadline | July 10, 2027 | Member-state deadline; Norway depends on EEA incorporation first |
| NO draft AML act section 8-4 | Proposed (not yet in force) | National hook planned for AMLD6 Art. 40 risk-based supervision |
What should compliance teams do before September 27, 2026?
Submit or coordinate comments if the draft's data fields, residual-risk methodology, or sector mapping would force costly retooling of your AML programme or client file architecture. Map the draft information asks against what you already produce for Advokattilsynet inspections and for section-level risk assessments under the Hvitvaskingsloven, and log gaps now.
Brief partners that future supervisory risk classification will be more standardised across EEA non-financial supervisors: residual risk after controls, not only inherent practice-area risk, will drive intensity of oversight. Align documentation so inherent risk, control effectiveness, and residual risk can be evidenced in the categories the RTS is likely to lock in. Continuous, per-jurisdiction monitoring of AMLA and Advokattilsynet publications surfaces these consultation openings the day they appear, before the comment window compresses.
How does this sit against Norway's AMLD6 transposition path?
This consultation is not Norway's AMLD6 transposition itself. It is the EU-level technical layer that Advokattilsynet is already tracking for advocates. EEA incorporation of AMLD6 and Regulation (EU) 2024/1624, followed by amendment of the Hvitvaskingsloven, remains the binding national track for expanding or refining lawyer AML duties. Treating the RTS consultation as early visibility into that supervisory model is the practical compliance move; treating it as already applicable Norwegian law is not.
Take advantage of this real-time watch
Next steps: (1) download the draft RTS and Annexes from AMLA and assign an owner for a gap analysis against your firm risk assessment; (2) decide by mid-September whether to file comments alone or via a bar association or network; (3) update the AMLD6 implementation roadmap so RTS data fields feed systems work before the 2027 transposition window. Obsidian tracks Advokattilsynet and AMLA AML developments so those milestones do not land as surprises.
