From 10 July 2027, the EU anti-money laundering regulation (AMLR) will begin to apply. Sellers of, among other things, jewellery and watches worth more than 10,000 euros (approx. 43,000 PLN) will have to verify the customer’s identity, but the rules do not explicitly mention a PESEL number for every purchase.
The basis is Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024. Its provisions start to apply on 10 July 2027. According to media reports, some entities, e.g. professional football clubs and football agents, will only be subject to the obligations from 10 July 2029.
Who Is Affected by the New Obligations
The regulation does not require every buyer to be identified. The obligation arises only when the transaction is carried out by an obliged entity, that is, one subject to AML rules. As the regulation’s preamble states, traders in goods generally cease to be covered by these obligations, with the exception of those dealing in precious metals, precious stones, other high-value goods and cultural goods.
In practice, as Polish media describe, this concerns, among others, sellers of jewellery, gold and watches, art galleries, auction houses and car dealers. For luxury cars the threshold is to be 250,000 euros, and for aircraft and boats 7.5 million euros. An ordinary car purchase for several tens of thousands of zloty should therefore not trigger this procedure.
The new obligations will also cover, among others, crypto-asset service providers, crowdfunding platforms and non-bank credit intermediaries.
What About the PESEL Number
According to commentaries on the rules, the regulation does not name the PESEL number explicitly. Instead, it specifies the scope of data needed to identify a natural person, and in Poland the PESEL number may serve as that identification number. The seller must establish who they are entering into a transaction with and check whether the customer is acting on behalf of another person. This will usually require presenting an identity document.
The value of the transaction matters, not the form of payment. Verification is to apply regardless of whether the customer pays in cash, by card or by bank transfer. The regulation also provides for an EU-wide limit on cash payments of 10,000 euros.
What This Means for Buyers
- When buying jewellery, a watch, gold or a work of art worth more than 10,000 euros, expect to be asked to show a document and provide identifying details.
- Purchases below this threshold in a typical shop will not be covered by this procedure.
- For cars the threshold is 250,000 euros, so this only affects the luxury segment.
- The amount in zloty depends on the euro exchange rate: 43,000 PLN is an approximate value.
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