FINMA online identification rules that took effect on 1 November let Swiss banks and other financial intermediaries onboard new clients using the state electronic identity, the e-ID, and require them to check that a live person is behind each request. The Swiss Financial Market Supervisory Authority announced the partial revision of its Circular 2016/7 on video and online identification on 8 October.
The change prepares the financial system for an identity credential that does not yet exist. Switzerland’s e-ID has been delayed, and its launch date has not been set. FINMA’s rules mean that once it arrives, it can be used to open an account remotely under anti-money-laundering law. The regulator says the new liveness requirement responds to “the growing risks associated with new technologies (particularly in the field of artificial intelligence)”.
In brief
- From 1 November, the Swiss e-ID can be used to identify clients onboarded online under anti-money-laundering rules.
- Intermediaries must confirm that the request comes from the client in person, through liveness detection.
- Documents with a QR code, such as the Swiss driving licence, now count the same as those with a machine-readable zone.
What the FINMA online identification circular now requires
The revised circular, adopted on 23 September, adds a new section on identification by electronic identity credentials. An intermediary “requires the presentation of electronic identity credentials issued in accordance with the e-ID Act of 20 December 2024”, checks that the credential was issued to the client and is valid, and verifies the client’s home address. It must also ensure “that the identification request originates from the contracting party (liveness detection)”, and document the process.
Liveness detection has also been added to the existing route that relies on a qualified electronic signature. Firms using that route get a one-year transitional period to make the technical changes for address checks and liveness detection. For the route where the firm checks photographs of the client and their ID, the circular already required the client’s photo to be taken during the identification process.
Two smaller changes widen the options. Identity documents with a QR code, such as the Swiss driving licence, are now treated like documents with a machine-readable zone. And address checks can now rely on “an equivalent digital process that reliably links the contracting party and its infrastructure to a place of residence”, alongside utility bills, post or registers. People onboarding on behalf of companies may also use the e-ID route.
FINMA said liveness detection was added after its public consultation, in response to concerns raised there. The regulator has been active on digital finance this year; it recently approved Switzerland’s first retail bitcoin ETF.
The e-ID itself has been held back by AI risks
The rules are written for a credential still in development. The Federal Office of Justice said on 30 June that recent developments in artificial intelligence had created “additional challenges” for issuing the e-ID, and that it would add technical measures to make it harder to plant malware on users’ devices and to strengthen the detection of deepfakes (TSN translation). The launch was postponed, with a date to be announced once that work is largely finished.
The office expects the underlying trust infrastructure to start operating in the first half of 2027, when the Federal Council will bring the e-ID Act at least partly into force, for example for electronic driving licences.
Liveness checks are the answer to cheap synthetic faces
The more immediate change for banks is liveness detection, not the e-ID. Remote onboarding has relied for years on a client holding an ID card up to a camera. Generative AI makes faked faces, voices and documents cheap, and a check that a real person is present at the moment of identification is a direct response. FINMA frames it as addressing AI-related risks without naming specific attack types; the Federal Office of Justice is more explicit, citing deepfakes as a reason for delaying the e-ID itself.
The approach is technology-neutral. The circular says what an intermediary must ensure, not how. That gives banks and identity providers room to choose methods, but it also means the standard of protection will vary until supervisors test it in practice. The one-year grace period for the electronic-signature route suggests FINMA expects some providers need real engineering work.
Other regulators are moving in the same direction. In the UK, the FCA has proposed updating its Financial Crime Guide to cover AI tools, and TSN has reported that 28% of UK adults think voice-clone scammers targeted them in a year. Switzerland’s move is narrower, but it puts the check into binding supervisory practice for every bank onboarding clients online.
The real test comes when the e-ID launches and banks start accepting it at scale; until the Federal Office of Justice sets that date, the new e-ID section of the circular has nothing to verify.
Sources
- FINMA: FINMA adopts partially revised Circular 2016/7 “Video and online identification” (8 Oct 2026)
- FINMA: Circular 2016/7, Due diligence requirements for client onboarding via digital channels, valid from 1 Nov 2026 (PDF)
- Federal Office of Justice: New timetable for the e-ID and trust infrastructure (30 Jun 2026, German)
Related stories
- FINMA Approves Switzerland’s First Bitcoin ETF Open to Retail Savers
- FCA Proposes Financial Crime Guide Update on APP Fraud and AI Tools
- 28% of UK Adults Think Voice-Clone Scammers Targeted Them in a Year
Image: Dodo von den Bergen / Wikimedia Commons, CC BY-SA 4.0, modified by TSN; this image is also CC BY-SA 4.0
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