Letting agents and the €10,000-a-month rent rule

If your firm manages lettings, you may have seen references to a new EU rule about tenancies with rent of €10,000 or more a month. It comes from Regulation (EU) 2024/1624 (the AMLR), the EU's new anti-money laundering rulebook, which applies directly in Ireland from 10 July 2027.

The rule is real, but it is widely misunderstood. Some agents read it as "lettings are now caught by AML law". Others read it as "lettings under €10,000 a month are exempt from everything". Neither reading is right for an Irish firm. This post explains what the threshold actually does, where it fits alongside your existing obligations, and what to start doing now.

What the AMLR actually says about letting agents

The AMLR widens the list of businesses in scope of EU AML rules — the regulation calls them "obliged entities". Among the additions: letting agents, but only in respect of tenancies where the monthly rent is €10,000 or more.

Two things follow from that.

First, this is an EU-wide scope rule. Across the EU, letting activity at that rent level is brought inside the single rulebook from 10 July 2027. For agents in some member states, that is genuinely new territory.

Second, the threshold defines when the AMLR's obligations attach to a letting transaction — it is not a general amnesty for everything below it. Which brings us to the Irish position.

Why Irish letting agents cannot treat this as new

Ireland is not starting from zero. Letting agents, estate agents, auctioneers and property management firms have been within the Irish AML framework as "designated persons" under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 for years, with the Property Services Regulatory Authority (PSRA) acting as both licensing body and AML competent authority for the sector.

So for an Irish lettings firm, the practical picture is this:

• Today: you already have AML obligations under the CJA 2010, supervised by the PSRA.
• From 10 July 2027: the AMLR replaces the substantive rulebook you have been working under. Its letting-agent scope rule, its lower thresholds and its prescribed compliance roles apply directly — no Irish transposition needed for the regulation itself. The institutional side (supervisors, FIU powers, registers) is handled separately by Directive (EU) 2024/1640 (AMLD6), which Ireland must transpose.

The risk is not that the €10,000 rule catches you by surprise. The risk is that your existing CJA 2010-era policies, risk assessment and thresholds quietly go out of date on the day the AMLR applies — while your PSRA licence and supervision carry on regardless.

What a high-rent tenancy will demand of you

Where a tenancy crosses the €10,000-a-month line, the AMLR's customer due diligence obligations attach to that relationship. In plain terms, expect to need:

• Identity verification of the parties you act for, using reliable documents or eIDAS-aligned electronic identification, which the AMLR explicitly recognises.
• Beneficial ownership checks where a party is a company or other legal entity. The AMLR harmonises the beneficial owner test at 25% or more ownership interest, direct or indirect, EU-wide. In Ireland that sits alongside your existing duty, since April 2021, to obtain an extract from the Register of Beneficial Ownership (rbo.gov.ie) before entering a new business relationship, and to report discrepancies between the register and what your own checks find.
• Enhanced due diligence in high-wealth situations. The AMLR introduces enhanced measures for relationships involving high-net-worth individuals — assets of €5 million or more handled for a client whose total wealth is €50 million or more. A tenant paying €10,000 or more a month in rent will quite often be exactly this profile, so build the trigger into your onboarding questions rather than treating it as an afterthought.

A clearly hypothetical example: imagine your firm is instructed to let a Dublin 4 property at €12,000 a month, and the prospective tenant is a company registered abroad. Under the AMLR you would be looking at identifying the company, working out who owns or controls 25% or more of it, obtaining and comparing beneficial ownership information, and considering whether the individuals behind it meet the high-net-worth enhanced due diligence tests. That is a materially heavier file than most lettings teams keep today.

The cash rules apply to lettings too

Separate from the rent threshold, the AMLR introduces two cash rules that lettings and property management teams should know:

• An EU-wide cap of €10,000 on cash payments for commercial transactions, whether as a single payment or a series of linked operations. This is directly applicable.
• Limited customer due diligence on occasional cash transactions of €3,000 or more.

If anyone in your office still accepts cash for deposits, rent or fees, your procedures need hard limits and escalation steps built in well before July 2027.

Reporting: what stays the same

Suspicious transaction reporting does not go away. In Ireland, STRs are dual-reported: to FIU Ireland via the goAML portal (fiu-ireland.ie) and to the Revenue Commissioners via ROS (revenue.ie). Your MLRO should be registered on both.

Two AMLR points to note for your procedures:

1. Requests from the FIU must generally be answered within 5 working days — shorter for some categories — so your records need to be retrievable, not buried in filing cabinets.
2. Records must be retained for 5 years and then deleted. Retention without deletion is itself a compliance gap under the new regime.

Ireland has no threshold transaction reporting regime — there is no obligation to routinely report transactions above a set amount, and the AMLR does not create one. Your reporting duty is suspicion-based.

What to do now

You have until 10 July 2027, but readiness work compounds. A sensible sequence:

1. Map your lettings book. Identify any current or likely tenancies at or near €10,000 a month, and decide how new instructions at that level will be flagged at intake.
2. Refresh your business-wide risk assessment against the AMLR's requirements rather than the CJA 2010 framework it was probably written for.
3. Review your CDD thresholds and forms. The occasional-transaction threshold drops to €10,000, occasional cash of €3,000 or more triggers limited CDD, and the beneficial owner test is harmonised at 25%.
4. Assign the prescribed compliance roles. The AMLR requires a board-level compliance manager plus a compliance officer of sufficiently high standing — the compliance officer also takes on responsibility for targeted financial sanctions implementation from 10 July 2027. Decide who holds these roles, even in a small firm.
5. Check your registrations. goAML, Revenue ROS for STRs, and RBO designated-person access (form BEN3A1) should all be in place and current.
6. Tighten cash handling. Written limits reflecting the €10,000 cap and the €3,000 occasional-cash trigger.
7. Log your training. Make sure lettings and property management staff — not just the sales side — are trained on the changes, and that the training is recorded.

Where CompliDesk fits

CompliDesk Ireland is being built AMLR-native for PSRA-licensed firms — risk assessments, CDD workflows and cash-rule warnings mapped to Regulation (EU) 2024/1624 from day one, not retrofitted. If you are unsure whether the new rulebook catches your lettings work, start with our am I in scope check.