The Swiss Financial Market Supervisory Authority FINMA has partially revised its practice in Circular 2016/7 “Video and online identification”. It has taken into account the latest technological developments, particularly with regard to the Federal Act on Electronic Identity Credentials and Other Electronic Credentials (E-ID Act), which is due to come into force.
Circular 2016/7 “Video and online identification” sets out FINMA’s practice regarding due diligence
obligations for client onboarding via digital channels. This partial revision takes particular account
of developments relating to the new Federal Act on Electronic Identity Credentials and Other Electronic
Credentials (E-ID Act), as well as the associated introduction of electronic identity credentials (e-ID).
Specifically, the e-ID can be used for identification purposes when onboarding clients via digital channels
under the AMLA. In addition to other selective adjustments, identification documents bearing a QR code
(e.g. the Swiss driving licence) will be treated as equivalent to those with an MRZ (machine-readable zone).
A public consultation was held on the partial revision of the circular. FINMA has taken into account
several concerns raised during the consultation and implemented them in the circular. Specifically,
liveness detection is now to be introduced as an additional security measure for online identification,
in order to address the growing risks associated with new technologies (particularly in the field of
artificial intelligence). Furthermore, digital processes that reliably link the contracting party and
its infrastructure to a place of residence are permitted for the purposes of place of residence
verification as part of the online identification process.
The changes will enter into force on 1 November 2026.
