FI AML 2027 – annual reporting, inherent risk & Fidac receipt | Word/PDF/Excel

How do you prepare for the FI's new periodic AML reporting in 2027 without losing control of figures, supporting documentation, and receipts? From 1 January 2027, the Swedish Financial Supervisory Authority's (FI) previous periodic AML questions will be replaced by a revised framework focusing on, among other things, inherent risks and control environments. The data normally pertains to 31 December 2026, and reporting takes place 1 January–31 March 2027 via the Fidac authority portal. This niche Word/PDF/Excel package helps an FI-supervised company get its question version, data sources, evidence of control, attestation, and actual portal receipt in order.

For whom? Companies that are both subject to the Swedish AML Act and supervised by the FI, such as certain banks, credit market, payment, and other financial institutions. It is not a general requirement for all Swedish small businesses. For certain companies affected by AMLA's direct supervision, special reporting instructions apply, which the FI contacts them about. Check your own eligibility and the FI's latest guidance before use.

Delivery: five Swedish operational templates, one Swedish guide and a separate English User Guide, each in editable Word (DOCX) and searchable, printable A4 PDF. In addition, an Excel (XLSX) workbook with nine tabs and 730 administrative formulas. Total 7 DOCX + 7 PDF + 1 XLSX = 15 customer files in a digital ZIP, one-time purchase of SEK 79. The PDF copies are not interactively fillable.

Exactly What Do You Get? File List

Excel – Nine Worksheets, 730 Formulas, and 21 Tests

The tabs are named Read Me, Overview, Scope, Questions, Risks, Controls, Evidence, Fidac, and Sources. The overview counts actual entities, entered question IDs, incomplete sources, control gaps, and items missing an actual portal receipt. No pre-filled customer, account, or transaction data is included.

Automatic internal statuses include “REVIEW REPORTING OBLIGATION”, “AMLA TRACK – FI INSTRUCTION”, “COMPLETE QUESTION”, “CHECK METHOD”, “REMEDY GAP”, “SUBMISSION NOT VERIFIED” and “CHECK PORTAL RECEIPT”. The latter does not mean that the FI has accepted the report – a designated person must review the actual receipt and any follow-up. 21 out of 21 scenario tests are passed, and the customer file is free of QA items.

How to Complete the Annual Reporting

1. Determine the reporting obligation. Verify the relevant license/registration, FI supervision, and applicable part of the AML Act. A group or branch may require special delimitation.
2. Obtain the correct question framework. Use the FI's current guidance and Fidac, and if necessary, EBA's technical package 4.4 phase 1 or a later version. Copy actual question codes and definitions – do not enter fabricated taxonomy codes.
3. Link the data owner and measurement method. Document the source, system version, population, reference date 31 December 2026, and the meaning of the data points.
4. Separate risk and controls. Inherent risk should not be confused with the actual effectiveness of the control environment or a finally determined regulatory risk class.
5. Review and attest. An independent internal control should confirm reconciliation, method, gaps, and authorized approval before information is submitted.
6. Report in the actual Fidac. The document package logs the workflow but does not upload files to the FI or generate EBA-XBRL or a completed authority form.
7. Check the actual receipt. Document the portal's receipt ID, date, and any reported validation errors. “Sent” in an internal register is not the same as an accepted authority report.

Legal and Technical Situation Ahead of 2027

The FI on 26 June 2026: The FI announced that the annual periodic AML reporting is being revised with new questions on inherent risk and control environment. The updated questions replace the previous ones. Read the FI's announcement.

The FI on 13 October 2026: EBA's technical reporting package 4.4 phase 1 provides more information on which questions and data points are expected for reporting in the first quarter of 2027. Reporting normally takes place via Fidac, while special AMLA-affected institutions must follow the FI's special instructions. See the FI's update.

EBA on 12 October 2026: The phase 1 package includes AMLA's eligibility templates and revised support for risk assessment data collection in 2027. Any later technical updates, hotfixes, and the FI's current reporting rules must be checked. Read the EBA publication.

Important limitation: The FI explicitly states that AMLA's development form should not be used as a reporting form to the FI. Therefore, the package contains no fabricated authority fields or claimed complete FI taxonomy. It is a structure for entering official data points once the company has verified the correct version.

Difference from Mallbutiken's Existing AML/KYC Package

The broad AML/KYC & AML Compliance 2026/2027 covers general risk assessment, customer due diligence, PEP, and ongoing AML work. This product is instead a specialist module for the 2027 FI reporting: source version, official questions, risk and control environment data, internal attestation, and actual Fidac receipt. They therefore do not compete for the same work steps.

Frequently Asked Questions

Must all Swedish companies do the FI's AML reporting?

No. This package is intended for companies that are both subject to the AML Act and supervised by the FI. Check the business's license and the FI's instructions before assuming a reporting obligation.

What is the reference date, and when is the report submitted?

The revised reporting takes effect on 1 January 2027. The FI states that the data must pertain to 31 December 2026 and that regular reporting takes place 1 January–31 March 2027. Check any special instructions for your institution.

Are the question IDs already filled in Excel?

No – intentionally not. They must be copied from the FI's or EBA's actual, applicable question framework and version-controlled. Fabricated IDs would be misleading.

Can the workbook submit the report to the FI?

No. The submission is made in the authority portal Fidac according to current instructions. Excel provides administrative follow-up but no technical portal connection, authority receipt, or official taxonomy export.

Can we treat a control policy as a performed control?

No. The templates separate documented policy, actually performed control, gaps, measurement method, and evidence of decision.

Do special rules apply to AMLA-affected companies?

Yes. The FI states that companies subject to special AMLA tracks are contacted separately and may report according to the relevant EBA taxonomy. Do not automatically decide on the reporting path based solely on Excel.

Does the package contain actual customer data or transactions?

No. The customer files are reset. Store actual sensitive data in the company's protected system and use only references in this workbook.

Are the Word/PDF documents legally approved forms?

No. They are AI-assisted, source-checked working templates, not FI forms, and have not been independently reviewed by legal counsel.

Sources, Transparency, and Technical Control

FI, new questions, 13 October 2026; FI, comprehensive changes, 26 June 2026; FI, periodic reporting; EBA, technical package 4.4; Act 2017:630.

Version 1.0, AI-assisted legal source check and document QA 9 November 2026. All 14 PDF pages have been checked for searchability and page boundaries, Excel has 730 formulas and 21 out of 21 passed scenario tests, the ZIP has 15 files. No external lawyer or the FI has reviewed the package. Production does not include any publication or automatic Digital Products file linking.