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FINMA’s 1 November onboarding changes add e-ID and route-specific liveness checks

The revised circular sets conditions for Swiss e-ID and other digital identification methods. A one-year technical transition applies specifically to the qualified-electronic-signature process.

FINMA announced on 8 October that its revised video and online identification circular will take effect on 1 November 2026. The text, adopted on 23 September, adds a Swiss e-ID route, accommodates eligible QR-based identity documents and updates safeguards against impersonation.[1][2]

The revision follows consultation from December 2025 to February 2026. It updates the evidence and checks available for digital customer identification within the existing anti-money-laundering framework.[3][1]

At a glance01

Requirements by onboarding route

Requirements by onboarding route
ProvisionRequirement or permissionImplementation scope
44.1–44.4: e-IDCheck issuance to the applicant and validity; verify residence, perform liveness detection and document the process.Separate credential, applicant and residence checks.Source 2
37.1: residenceAn equivalent digital process may reliably link the applicant and their infrastructure to a residence.An equivalent digital method for the residence requirement.Source 2
39 and 54: qualified signatureResidence verification and liveness adjustments receive a one-year technical transition from entry into force.Limited to technical changes for the qualified-signature route.Source 2

Keep each identity check visible

The permitted routes address document authenticity, the link to a live applicant and residence. A valid credential alone cannot answer all three questions. The operational record should identify the evidence and checks used for the particular route.[1][2]

The qualified-signature transition

Margin number 54 provides one year from entry into force for the technical changes to residence verification and liveness detection under the qualified-electronic-signature route in margin number 39. The other changes retain their applicable 1 November start.[2]

A provider supporting several methods should therefore map each process to its own requirements and transition. Adoption on 23 September, announcement on 8 October and entry into force on 1 November are distinct dates in that implementation.[1][2]

Follow the evidence

Sources & further reading

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