Is the external expert exam required every year?

Yes, but in the two years following a full report it may be replaced by a follow-up report, limited to verifying that the deficiencies previously identified have been corrected. The usual cycle is: full → follow-up → follow-up → full.

Is the follow-up report automatic?

No — it is an option, not an obligation. If the year brought significant changes (a new business line, a merger, a change of ownership), the prudent choice may be a full report even if a follow-up was 'due'.

Full report or follow-up report? The three-year cycle

The exam is annual, but in the two years following the issuance of a full report it may be replaced by a follow-up report, referring exclusively to the correction of the deficiencies previously identified. The usual cycle is: full → follow-up → follow-up → full.

The full report describes and assesses the entire prevention system. The follow-up answers a narrower question: was what was wrong actually fixed? That is why its scope — and its cost — is smaller.

Three practical tips from someone who has performed more than 900 exams:

Do not skip years. In an inspection, SEPBLAC asks for the full history: a one-year gap with no report (full or follow-up) is a finding in itself.
The follow-up is not automatic. It is an option, not an obligation: if the year brought significant changes — a new business line, a merger, a change of ownership — the prudent choice may be a full report even if a follow-up was "due".
Keep the three reports of the cycle together, along with the minutes showing that the deficiencies reached the governing body.

Legal basis:

Art. 28.1 of Ley 10/2010
Order EHA/2444/2007

Reviewed: August 2026 · PBK Asesores — external experts in AML/CTF before SEPBLAC since 2010, more than 900 exams performed.

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