What Changed
- Permitted the use of the new Swiss e-ID for client onboarding under AMLA and recognized QR-code identity documents as equivalent to MRZ documents.
- Introduced mandatory liveness detection as an additional security measure to counter artificial intelligence risks during online identification.
- Allowed digital processes that link contracting parties and their infrastructure to a residence for place of residence verification.
Financial institutions, digital onboarding service providers, and clients seeking to open accounts via digital channels in Switzerland are directly affected by newly adopted regulatory guidance from the Swiss Financial Market Supervisory Authority (FINMA). On 8 October 2026, FINMA announced the adoption of a partial revision to Circular 2016/7, titled “Video and online identification,” which sets out the supervisory authority's practice regarding due diligence obligations for client onboarding via digital channels under the Anti-Money Laundering Act (AMLA).
The partial revision takes particular account of developments relating to the new Federal Act on Electronic Identity Credentials and Other Electronic Credentials (E-ID Act) and the associated introduction of electronic identity credentials (e-ID). Under the updated circular, the e-ID can be used for identification purposes when onboarding clients via digital channels under AMLA framework rules. Furthermore, selective adjustments mean that identification documents bearing a QR code—such as the Swiss driving licence—will be treated as equivalent to those featuring a machine-readable zone (MRZ).
Following a public consultation process, FINMA incorporated several concerns raised by stakeholders into the final circular. To address growing risks associated with emerging technologies, particularly in the field of artificial intelligence (AI), liveness detection is introduced as an additional security measure for online identification. Additionally, digital processes that reliably link the contracting party and its infrastructure to a place of residence are now permitted for verifying place of residence during the online identification process.
The partially revised Circular 2016/7 will enter into force on 1 November 2026. Supervised financial entities and legal compliance teams operating in Switzerland must ensure their identity verification systems and digital onboarding workflows conform to these updated standards by the entry-into-force date.
Who May Be Affected
Financial intermediaries, compliance personnel, technology vendors, and clients undergoing digital onboarding in Switzerland under AMLA.
Cross-Border Context
Relevant to international institutions, fintech providers, and cross-border clients accessing financial services in Switzerland through digital channels.
What to check next
- Access the published revised FINMA Circular 2016/7 text on FINMA's official web portal.
- Review organizational technical requirements for integrating liveness detection and e-ID verification prior to 1 November 2026.
This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.