FINMA Circular 2016/7: Partial revision on video and online identification

Background to the partial revision

FINMA Circular 2016/7 sets out how financial intermediaries meet their due diligence requirements under the Anti-Money Laundering Act (AMLA) when they establish business relationships through digital channels, for example via video identification, online identification, or a qualified electronic signature. The partial revision was triggered by the Federal Act on Electronic Identity Credentials and Other Electronic Credentials (E-ID Act). FINMA is also responding to new fraud risks posed by artificial intelligence, deepfakes, and synthetic identities.

A public consultation on the partial revision ran from December 2025 to February 2026. fidentity also submitted a response. We already reported on the consultation draft in February 2026. On September 23, 2026, FINMA adopted the circular in its final form. The following sections show what changes in practice.

E-ID and ID documents with a QR code

Financial intermediaries can now identify their customers using the e-ID. They verify that the e-ID was issued to the contracting party and is valid, and they document the process. The e-ID can be used once the E-ID Act takes effect, expected in 2027. The following applies:

• Only the Swiss e-ID under the E-ID Act is accepted, and only for online identification, not for video identification. According to FINMA’s consultation report, foreign e-IDs, for example under the EU eIDAS Regulation (EUDI wallets), are currently not provided for.

• For corporate customers, the persons acting on behalf of the legal entity can now also be identified using a QES, digital authentication, or the e-ID (margin no. 43.1). An extract from the relevant register and the document specifying the power of attorney are still required, as is place of residence verification for QES and the e-ID.

In addition, ID documents with a QR code (such as the new driver’s license) are now treated as equivalent to documents with a machine-readable zone (MRZ) for both video and online identification.

Liveness detection in online identification

With liveness detection, the financial intermediary verifies that a physically present person is actually being identified and that there is no manipulation using a photo, video, or deepfake. The circular words the requirement as follows: “In addition, the financial intermediary ensures that the identification request originates from the contracting party (liveness detection).” (margin no. 39, p. 8)

Previously, liveness detection was required for electronic copies of identification documents authenticated by the financial intermediary. It now also applies to QES and the e-ID. For the e-ID, it was not yet included in the consultation draft. This makes liveness detection one of the most significant tightenings in the partial revision.

Place of residence verification in online identification

Place of residence verification is now also required for QES and the e-ID. Permitted methods are a utility bill, postal delivery, a public register or a trustworthy, privately managed database, and an equivalent digital process that reliably links the contracting party and its infrastructure to a place of residence. According to the explanatory notes, this includes geolocation.

The reason: FINMA classifies identification by QES or e-ID as onboarding by correspondence, that is, without personal contact. For QES, the explanatory notes attribute this to the fact that since 2022 a QES can be issued through unattended remote identification, meaning without a live conversation with the issuer. There is no direct personal interaction. The financial intermediary must therefore additionally verify the place of residence (Article 45 para. 2 AMLO-FINMA).

Effective date and transition periods

The partially revised circular takes effect on November 1, 2026. From that day, the new requirements apply without a transition period, including liveness detection and place of residence verification. For online identification by electronic copy of an identification document, this includes verifying the origin of the bank transfer. For the technical adjustments to QES, FINMA allows one year: liveness detection and place of residence verification must be implemented there by the end of October 2027 (margin no. 54).

The partial revision contains no new provisions on the involvement of third parties: the rules on this (margin no. 51) remain unchanged.

Actions required for financial intermediaries

• Add liveness detection and place of residence verification to QES processes – by the end of October 2027 at the latest
• Set up the e-ID process with liveness detection, place of residence verification, and documentation from the start
• Define which ID documents with a QR code you accept
• Verify the origin of the bank transfer – payments via PayPal, Twint, or credit card issuers are not sufficient
• Update internal policies and process descriptions