The Swiss Financial Market Supervisory Authority (FINMA) announced on 8 October 2026 that it has adopted a partial revision of its Circular 2016/7 "Video and online identification". The text sets out FINMA's practice on due diligence obligations when a business relationship is opened through digital channels, within the meaning of the Anti-Money Laundering Act (AMLA). The amendments will enter into force on 1 November 2026.
This is a circular, in other words an instrument through which the supervisory authority specifies how it applies the law in force. Its scope covers financial intermediaries subject to the AMLA that identify their clients remotely, by video or online.
The e-ID accepted for remote onboarding
According to FINMA, the revision takes account of the latest technical developments and, in particular, of the Federal Act on Electronic Identity and Other Electronic Means of Proof (e-ID Act), whose entry into force has been announced. In practical terms, the electronic identity (e-ID) may be used for identification purposes when a business relationship subject to the AMLA is established through digital channels.
The press release does not specify when the e-ID Act itself will enter into force. In practice, the possibility of using the e-ID in an account opening process will therefore depend on the actual availability of this electronic identity to clients.
Documents with a QR code treated like those with an MRZ
Among other selective adjustments, FINMA states that identity documents bearing a QR code, such as the Swiss driving licence, will be treated in the same way as documents with a machine-readable zone (MRZ).
What the consultation changed
The revision was the subject of a public consultation. FINMA says it took into account several concerns raised during the consultation and incorporated them into the circular. Two points are highlighted in its press release.
First, liveness detection must now be introduced as an additional security measure for online identification. The stated aim is to address the growing risks associated with new technologies, particularly in the field of artificial intelligence. The point is to verify that a real person is actually behind the screen at the time of identification, rather than an image, a recording or artificially generated content.
Second, for the verification of the place of residence as part of online identification, FINMA accepts digital processes that reliably link the contracting party and their infrastructure to a place of residence.
What this means for banks and fintechs
For institutions that open accounts remotely, whether traditional banks, digital banks or other financial intermediaries, the revision broadens the recognised means of identification (e-ID, documents with a QR code) and the options for verifying residence. At the same time, it adds a security requirement, liveness detection, for online identification.
As we read it, the circular thus combines two movements: an easing in favour of fully digital customer journeys and a tightening of controls against fraud assisted by artificial intelligence. The institutions concerned have little time, as the entry into force comes about three weeks after publication.
What remains to be clarified
FINMA's press release remains general on several points. It does not detail the technical requirements expected for liveness detection, nor the criteria for judging that a digital process "reliably" links a client to their place of residence. Nor does it mention any transitional provisions. These elements must be sought in the text of the revised circular and in the documents published by FINMA.
Finally, the use of the e-ID remains tied to the timetable of the e-ID Act, about which the press release states only that it is due to enter into force. FINMA's announcement opens up a regulatory possibility; it does not guarantee that every institution will incorporate it into its processes from 1 November 2026.
