The Ministry of Justice has opened consultation on proposed AML/CFT levies. While no levy has been finalised, reporting entities now have the opportunity to consider whether the proposed approach is fair, proportionate, and workable.
The proposal is for a risk-based levy rather than a flat charge across all reporting entities. It looks at who may need to pay, how costs could be allocated, and whether smaller businesses should be excluded.
For reporting entities, the key question is whether the proposed design properly reflects risk, size, and the realities of different business models.
The Ministry’s preferred direction appears to be a more targeted approach, with larger or higher-risk entities more likely to contribute. For some sectors, this may involve a tiered model based on transaction values or customer numbers, rather than a simple flat rate.
The consultation also explains that the levy would help fund parts of the AML/CFT system, including supervision, intelligence, and wider system support. The argument is that a better-resourced system should be more effective, more responsive, and easier to work with over time.
A practical way to assess the proposal is to ask: would the levy design be fair and workable for our business or sector?
That includes considering:
- Whether your sector is proposed to be levied.
- Whether the basis for charging makes sense.
- Whether smaller entities are treated appropriately.
- Whether the overall approach seems fair and proportionate.
At this stage, the key point is that consultation is open and there is still an opportunity to provide feedback before the levy settings are decided.
How to make a submission
Submissions can be made through the Ministry of Justice consultation page and are open until 5.00 pm on Friday, 10 April 2026. The same page also includes registration links for two free online public presentations on the levy proposals, including an introductory session and a final Q&A session. Learn more.
We’ll continue to keep you informed as the consultation progresses and as more detail emerges on what the final levy approach may mean in practice.
Useful links
Consultation Document and Engagement Programme