FINMA’s revised video and online identification circular takes effect on 1 November. The regulator announced the changes on 8 October after adopting the revision on 23 September. The text broadens digital-identification routes while specifying checks that link the identity document to the person opening the relationship.[1][2]
What changes in the revised circular
| Area | Relevant detail |
|---|---|
| Electronic identity | Recognises credentials issued under Switzerland’s e-ID Act for the specified identification processSource 1Source 2 |
| Identity-document technology | Accepts qualifying QR-code documents alongside machine-readable-zone documentsSource 1Source 2 |
| Residence | Provides digital verification methodsSource 1Source 2 |
| Liveness | Adds or clarifies checks that the person is present in the relevant online routeSource 1Source 2 |
| Commencement | 1 November 2026Source 1Source 2 |
| Technical transition | One year for the residence and liveness requirements specified for qualified-electronic-signature identification under margin number 39Source 1Source 2 |
The transition is narrower than the whole circular
Margin number 54 grants the technical implementation period for the specified requirements in the qualified-electronic-signature route. It should not be described as a general one-year delay to every change, or omitted in a claim that all new checks must be operational on 1 November.[2]
The practical question for an onboarding team is which route its customer journey actually uses. Video identification, an approved electronic identity and a qualified electronic signature are not interchangeable process labels. The evidence and controls should follow the relevant route rather than a generic claim that an account is “digitally verified”.
Document validation, identity matching and residence evidence also answer different questions. A readable document can establish what it says without establishing who is presenting it. The revised requirements address those separate steps within the applicable anti-money-laundering framework.[2]
Sources & further reading
- FINMA revises video and online identification rules FINMA · 8 Oct 2026 · Accessed 27 Oct 2026
- Circular 2016/7, Video and online identification, revision of 23 September 2026 FINMA · 23 Sep 2026 · Accessed 27 Oct 2026