FINMA Circular 2016/7 Revision: e-ID, QR Codes and Liveness Checks

On 8 October 2026 FINMA published a partial revision of FINMA Circular 2016/7 “Video and online identification”, the circular that sets out how Swiss financial intermediaries meet their Anti-Money Laundering Act (AMLA) due diligence duties when a client relationship is opened through a digital channel. FINMA adopted the amendments on 23 September 2026, and they enter into force on 1 November 2026.

The revision changes the evidence that each onboarding route has to produce. Identification by qualified electronic signature (QES) now needs a residential address check and liveness detection. Identity documents with a QR code join those with a machine-readable zone (MRZ). The federal e-ID becomes an admissible document for online identification. The bank transfer used as a security element is now tied to a check on where the payment actually came from, and the circular’s direct scope narrows to FINMA-supervised intermediaries.

The parts run on different clocks. Some apply on 1 November 2026, one gets a one-year transitional period, and the e-ID provisions wait on a federal credential that, according to the Federal Department of Justice and Police, has no launch date yet. An onboarding team needs to know which is which before the internal directive is rewritten.

Related reading: FINMA Circular 2017/6 Consultation: Direct Transmission Without a List

FINMA Circular 2016/7 revision: dates and status

The dates below come from FINMA’s press release, the revised circular, the explanatory report and the consultation report, all published on 8 October 2026, and from the federal statements on the e-ID.

FINMA’s own expectation for the E-ID Act moved during this rulemaking. FINMA’s consultation press release of 16 December 2025 expected the E-ID Act to enter into force in mid-2026. In its explanatory report dated 23 September 2026, FINMA expected it in 2027. That shift explains the oddity of a circular section that applies from 1 November 2026 to a credential nobody can yet present.

This is the third partial revision. The circular was issued on 3 March 2016 and amended with effect from 1 August 2018 and 1 June 2021. The 2026 list of modifications adds margin nos. 43.1, 44.1 to 44.4 and 54, modifies margin nos. 2, 6, 14, 15, 31.3, 32, 33, 37.1, 39, 45 and 53, and changes two headings: it adds the Section IV.C title after margin no. 44 and renames Section IX, after margin no. 53, from “Abrogated” to “Transitional provision”. Margin no. 54 is a recycled number: it was added in 2018, abrogated in 2021, and now returns as the new transitional rule. The circular is available in English, German, French and Italian; the explanatory report and the consultation report exist only in German and French, so the renderings of those two reports below are my translations.

The margin numbers that changed, side by side

The quickest way to re-map an onboarding directive is margin number by margin number. The left column is the version last amended on 6 May 2021; the right column is the text in force from 1 November 2026.

What did not move matters as much for scoping the work. The video identification process in Section III keeps its structure: live audio-visual interview, trained staff, full audio recording, photographs of the client and the document, and the stop rules in margin nos. 18 to 22. The digital authentication route in margin nos. 40 and 41, the beneficial ownership declaration methods in Section V and the third-party rules in margin no. 51 are also unchanged.

Who the circular reaches after the margin no. 2 change

The old margin no. 2 pointed at Article 2 paragraph 2 of the AMLA as a whole. FINMA’s explanatory report points out that this also captured financial intermediaries that FINMA does not supervise: casinos and operators of large-scale games under the Gambling Act, and assayers and group companies under Article 42bis of the Precious Metals Control Act. By narrowing the reference to letters a to d quater, the revision limits the circular’s personal scope to the intermediaries FINMA supervises.

Margin nos. 3 and 4 still do their work for self-regulation. References to the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA) are read as references to the analogous provisions of the Swiss banks’ code of conduct on due diligence (CDB) and of the insurance association’s self-regulatory organisation, and SRO regulations that refer to the circular pick up its content when it enters into force.

Two reading traps sit in this section. The first is the acronym. In this circular “AMLA” is the Swiss Anti-Money Laundering Act of 10 October 1997 (SR 955.0). In EU material the same letters denote the EU Authority for Anti-Money Laundering, and a group policy that mixes Swiss and EU sources can end up citing the wrong one.

The second is size. The circular draws no distinction by size or risk category, so a bank that uses the relief in the FINMA small banks regime applies the same onboarding standards as a large bank.

Online identification with the e-ID: margin nos. 44.1 to 44.4

The new Section IV.C is four margin numbers long. The financial intermediary requires the client to present an electronic identity credential issued under the E-ID Act of 20 December 2024 (BBl 2025 20). It checks that the e-ID was issued to the contracting party and is valid. It verifies the residential address under margin nos. 34 to 37.1 and ensures through liveness detection that the identification request originates from the contracting party. It documents the identification process.

The technological neutrality table in margin no. 53 adds the legal hook: an e-ID is a valid identification document within the meaning of Article 45 paragraph 3 AMLO-FINMA for onboarding via digital channels.

The consultation report records that a majority of respondents criticised the extra address verification for the QES and e-ID routes. FINMA kept it: identification by QES or e-ID qualifies as onboarding by correspondence, and Article 45 paragraph 2 AMLO-FINMA requires the address to be confirmed by postal delivery or in another similarly conclusive way when onboarding starts without personal contact. Presenting an e-ID therefore covers the identity document, while the address check stays a separate step.

The e-ID is also confined to online identification. Several respondents asked for it to be usable in video identification, since video identification is treated as equivalent to in-person identification. FINMA declined. Its reasoning in the consultation report is practical: video identification assumes a document that can be visually checked for security features, while an e-ID has no MRZ or QR code to read, no copy of it can be made and archived, and asking staff to photograph “all relevant pages” of an e-ID during the video call makes no sense.

Then there is timing. The explanatory report says FINMA wanted intermediaries to be able to use the e-ID from the entry into force of the federal E-ID Ordinance, and that it skipped the usual pre-consultation for that reason. The federal schedule has since slipped. On 30 June 2026 the Federal Department of Justice and Police said the e-ID launch is delayed for privacy and security work, that the exact date will be announced once that work is largely complete, and that the trust infrastructure is expected to start operating in the first half of 2027, with the Federal Council bringing the E-ID Act into force at least partly at that point.

The law itself was accepted at the ballot on 28 September 2025. Margin nos. 44.1 to 44.4 carry no transitional period, but until the credential exists they have nothing to apply to.

Qualified electronic signature route: the address check and the one-year transition

Margin nos. 38 and 39 let an intermediary treat an electronic copy of the identity document as authenticated when the client signs with a QES from a certification service provider recognised in Switzerland under the Federal Act on Electronic Signatures (SR 943.03). Until now the only additional step was to check the identity document against the QES profile.

The explanatory report explains why that was enough in 2016 and in 2021, and why it no longer is. When the circular entered into force and when it was last revised in 2021, a QES could only be obtained by appearing in person or through video identification, which FINMA’s practice equates with in-person appearance. Since March 2022, the annex to the Federal Office of Communications (OFCOM) ordinance of 23 November 2016 on certification services (SR 943.032.1) has allowed a QES to be obtained, under certain conditions, through unattended remote identification, with no live conversation between applicant and issuer. FINMA’s practice treats that as equivalent to onboarding by correspondence, which brings in the Article 45 paragraph 2 AMLO-FINMA address confirmation.

Revised margin no. 39 therefore adds two steps: verification of the residential address under margin nos. 34 to 37.1, and liveness detection to ensure that the identification request originates from the contracting party. One respondent argued in the consultation that QES issuance already involves liveness checks, face matching and ETSI-conformant validation, giving more assurance than the circular’s own document-copy route. FINMA kept the address check, added liveness detection at the request of other respondents who pointed to deepfake risks, and granted time.

That time is in margin no. 54: transitional periods of one year from the date of entry into force apply so that intermediaries can make the necessary technical adjustments to the place of residence verification and liveness detection processes for QES identification under margin no. 39. The consultation report’s closing section mentions only the address check, but the circular text covers both steps, and the circular is the operative instrument. The transition applies to margin no. 39 alone.

One request went nowhere. A respondent asked FINMA to accept identity-linked electronic signatures with a clean audit trail as equivalent to a QES. FINMA declined, on the ground that advanced signatures generally lack the institutional and regulatory safeguards that a QES under the Federal Act on Electronic Signatures carries.

Liveness detection: what FINMA means by it, and where it now applies

The circular uses the term without defining it. The definition sits in the explanatory report: liveness detection means technical procedures that check whether the contracting party is actually a physically present, living person, and not a manipulation using photos, videos or other means of deception. The report adds that combining address verification with liveness detection helps to reduce the risk of fraudulent identification substantially.

The duty now appears in three places, in two wordings:

• Margin no. 32 (online copy checked by the intermediary): the intermediary ensures that the photograph of the contracting party was taken during the identification process.
• Margin no. 39 (QES) and margin no. 44.3 (e-ID): the intermediary ensures that the identification request originates from the contracting party.

For the margin no. 32 route the substance is not new: the 2021 text already required the intermediary to ensure the client photo was taken during the identification process; the consultation report describes margin no. 32 as already providing for liveness detection and explains the extension to the other online routes by the documented rise in fraud risk from new technology. Consultation respondents pointed to AI tools and deepfakes. FINMA cited its own Guidance 02/2026 on digital fraud risks, published on 9 April 2026 after a survey of 19 banks at the end of 2025, which names the risk of digital fraud when client relationships are established online and points to a need for action in operational risk management and money laundering prevention. The FATF fraud roadmap for 2026 to 2028 treats the same convergence of fraud and AML controls at international level.

What the circular does not do is prescribe a technology, a certification scheme or a vendor standard for liveness detection. That fits FINMA’s technology-neutral stance, but FINMA also refused a respondent’s request to replace the detailed rules with a non-exhaustive catalogue of acceptable identification and verification elements. The method is the intermediary’s choice; the circular states only the outcome it has to ensure. The explanatory report adds that staff are to be trained regularly on these developments under margin no. 8, which governs the employees who run video identification.

One respondent asked FINMA to state in the circular that its requirements are minimum standards to be supplemented on a risk basis. FINMA agreed with the substance and left the text alone, saying the circular’s practice is always a minimum and that additional security measures follow from the requirement for appropriate risk management, depending on the intermediary’s risk situation and business model.

QR-code identity documents: the Swiss driving licence case

Under the 2021 text, only identity documents with an MRZ could be used for video or online identification. The explanatory report gives a domestic example of the gap: the Swiss credit-card driving licence in the new design introduced on 15 April 2023 carries a QR code on the back for verifying the holder’s data and no longer has an MRZ. FINMA’s press release names the Swiss driving licence as the example of a QR-code document now treated as equivalent to one with an MRZ.

The revised margin nos. 6, 14, 15, 31.3 and 32 now refer to an MRZ or a QR code. The security-feature requirements stay: for video identification the document must also carry optical security features such as holographic-cinematic marks or printed elements with latent image effects, and the intermediary examines one optically variable and one randomly selected security feature; for the online copy route it checks at least two randomly selected security features.

Accepting QR-code documents is a permission. The explanatory report reminds intermediaries that they remain responsible for AMLA compliance and decide for themselves which identification documents they consider secure enough for opening relationships, pointing to Article 9 of the CDB 20, which names passport, identity card and driving licence as examples of official documents. FINMA expects the share of documents that carry only a QR code to be small for now. It also refused to open the rule to other future technologies such as data matrix codes, on the ground that an open clause would increase uncertainty about processes, interpretation and application; it says it evaluates new technologies regularly with a view to future partial revisions.

The margin no. 33 bank transfer: where the payment actually came from

The bank transfer is the extra security element in the online copy route. The intermediary arranges to receive a payment from an account in the client’s name at a bank in Switzerland or Liechtenstein, or at a bank in a FATF member state that its mutual evaluation did not rate non-compliant on the customer due diligence and wire transfer recommendations or low on immediate outcomes 3 (supervision) and 4 (preventive measures). The point of the transfer is that the client has already been identified once by a bank to an AMLA-compliant standard. For this purpose “bank” includes persons under Article 1b of the Banking Act.

The revision adds one clause: the intermediary checks whether the transfer actually originates from such a bank. The explanatory report says why. FINMA found in its supervisory activity that not all intermediaries verify the bank identity of the service provider that sends the payment. Credit card issuers, PayPal and Twint, and providers such as an authorised payment institution licensed in the United Kingdom or an e-money institution in Ireland, can execute payments without meeting the licensing conditions of the Banking Act, and they do not count as a bank under the circular. The intermediary has to check the origin of the transfer and make sure it comes from a provider comparable, in regulation and supervision, to an institution licensed as a bank in Switzerland.

That is a published supervisory finding, and it describes a specific control gap: a payment that lands with the client’s name on it can still have been sent by a non-bank. The circular does not say how the origin check is to be performed, and margin no. 54 gives it no transition, so it applies from 1 November 2026.

The consultation tested the edges of this rule. Some respondents wanted transfers from securities firms, payment service providers such as card issuers, Twint or PayPal, or virtual asset service providers to qualify, and one asked FINMA to drop the bank transfer altogether. FINMA kept the scope at banks, including persons under Article 1b of the Banking Act, and said that abandoning the transfer without other flanking measures, such as reading the chip of a biometric document, would reduce security and raise fraud risk. The chip-reading alternative in margin no. 33.1, introduced in 2021, remains available.

FINMA’s consultation draft of 16 December 2025 also offered a “reverse” bank transfer in margin no. 33: the intermediary would send the client an identification code by a payment to an account in the client’s name at a bank in Switzerland or Liechtenstein, instead of receiving a payment from the client. Part of the respondents welcomed it, and the consultation report notes that the idea originally came from the industry. The report also records that the Swiss Bankers Association pointed to abuse risks tied to transmitting an identification code: the receiving bank does not necessarily match the account holder data, and a prospective client could name any account at a third bank and pass the code on to someone else. Citing those reservations and the lack of consensus, FINMA dropped the option from the final text.

Address verification: an equivalent digital process replaces the geolocation bullet

Margin nos. 34 to 37.1 list the ways to confirm the residential address: a tax or other official invoice or a utility bill, postal delivery, a public register or a trustworthy privately managed database or directory, and, from 1 November 2026, “an equivalent digital process that reliably links the contracting party and its infrastructure to a place of residence”. The last bullet replaces the word “geolocation”.

Geolocation stays available: the consultation report says FINMA dropped the explicit mention because geolocation falls under the broader category of equivalent digital processes. The explanatory report describes the infrastructure as the client’s computer, mobile phone and similar devices, and states that digital residence confirmations issued by municipalities satisfy the circular. The consultation report adds that digitally issued residence confirmations from authorities could already be used under the previous text, as output of a public register.

Utility bills remain on the list even though FINMA agreed in the consultation report that they are prone to forgery. The new bullet sets the test, reliability of the link between person, infrastructure and residence, and leaves the method to the intermediary. The change matters beyond the online copy route, because margin nos. 39 and 44.3 both import margin nos. 34 to 37.1, so whichever address methods an intermediary approves now also serve its QES and e-ID flows.

Legal entities and partnerships: margin no. 43.1

Until now, for online identification, margin nos. 42 to 44 sent the identification of a legal entity’s representatives only through the online copy route in margin nos. 32 to 37.1. New margin no. 43.1 makes QES identification (margin nos. 38 and 39), digital authentication (margin nos. 40 and 41) and the e-ID (margin nos. 44.1 to 44.4) available as alternatives. The extract from the commercial register or a trustworthy directory and the power of attorney under margin no. 44 are still required.

Two consultation points help with scoping. Respondents suggested the verifiable LEI (vLEI) as a tool for representing legal entities and their representation rights digitally; FINMA said it can help with that but does not replace identification of the natural persons opening the relationship. Respondents also asked FINMA to state that no address check is needed for persons acting for a legal entity. FINMA left margin no. 43.1 unchanged and noted that a legal entity can always be onboarded under the existing margin nos. 40 and 41 without an address check.

Requests FINMA turned down

The consultation report is as useful for what it rejects as for what it adopts, because each rejection closes off a design option an onboarding team might otherwise build towards:

• Recognition of electronic identification under the EU eIDAS Regulation (Regulation (EU) No 910/2014): not currently foreseen. FINMA notes that the Swiss e-ID is designed as a national system and is not automatically recognised in dealings with the EU, and that eIDAS credentials cannot be admitted for identification under the circular without further technical and regulatory review in Switzerland.
• The e-ID in video identification: refused, as described above.
• Advanced or identity-linked electronic signatures as a substitute for a QES: refused.
• Bank transfers from non-bank payment providers, securities firms or virtual asset service providers: not introduced. The “reverse” transfer offered in the consultation draft was also dropped.
• A general clause for future document technologies, and a non-exhaustive catalogue in place of detailed rules: refused.

The eIDAS point is where Swiss and EU onboarding design part ways. In the EU, the Authority for Anti-Money Laundering’s final draft regulatory technical standards on customer due diligence under Article 28(1) of Regulation (EU) 2024/1624 specify the attributes that electronic identification means and qualified trust services should be able to provide, with alternative verification methods for customers who cannot use them. According to AMLA’s September 2026 factsheet, those standards remain subject to review by the European Commission and become definitive only on publication in the Official Journal; our article on the AMLA final RTS on CDD data and group-wide rules covers the EU side. A group running one digital onboarding stack for Swiss and EU entities cannot assume that an eIDAS-based flow satisfies Circular 2016/7.

Turning the revision into an onboarding change log

The revised circular is short enough that the change log can be built route by route. For each digital route an intermediary operates, the questions are which margin numbers govern it after 1 November 2026 and whether the change applies immediately or under margin no. 54.

• Online copy route (margin nos. 32 to 37.1): add the margin no. 33 origin check from 1 November 2026, decide whether to accept QR-only documents, and decide which digital address processes meet the margin no. 37.1 reliability test.
• QES route (margin nos. 38 and 39): plan the address verification and liveness detection steps within the one-year transition, including whether the QES provider, the intermediary or a third party performs them.
• Digital authentication (margin nos. 40 and 41): no change to the route itself; it becomes available for legal entity representatives under margin no. 43.1.
• e-ID route (margin nos. 44.1 to 44.4): design against the four steps now, with go-live tied to the federal launch.
• Video identification (Section III): add QR-code documents to the accepted list if the intermediary chooses to.

Where identification is outsourced, margin no. 51 still requires the intermediary to check that the mandated person or company has the professional knowledge and technology to process the identification documents of the relevant countries, and to receive and file the photographs, recordings, declarations and documentation the third party generates. The margin no. 53 table, unchanged on this point since 2021, also states that where an intermediary uses another financial intermediary, and that party entrusts video and online identification to a directly mandated service provider, the provider is not treated as a further sub-contractor. Where an identification vendor runs the flow, margin no. 51 keeps the verification duty with the intermediary, so the vendor’s service description and file layout can be checked against the new liveness and address steps and the documentation duties in margin nos. 31.4 and 44.4.

FINMA’s explanatory report expects the new options to make online identification more attractive and to support new business models, in particular for neobanks and fintech companies. The e-ID part of that expectation turns on a federal launch date that FINMA does not set.

Frequently Asked Questions

Does onboarding with the e-ID still require the margin no. 33 bank transfer?

Section IV.C lists four steps: present an e-ID, check that it was issued to the client and is valid, verify the address with liveness detection, and document the process. It contains no bank transfer, and margin no. 33 belongs to the online copy route in Section IV.B.a. My reading is that the circular does not require a transfer for the e-ID route. FINMA’s statement that the circular sets minimum standards leaves room for an intermediary to add one on a risk basis.

Our QES provider already runs liveness checks and face matching when it issues the certificate. Does that satisfy margin no. 39?

The circular places the duty on the financial intermediary and does not say whether a check performed by the QES issuer at certificate issuance counts. The consultation report records this argument for the address check, and FINMA still kept the address check and added liveness detection to margin no. 39. I would not treat an issuance-time check as discharging margin no. 39 without documenting how it links to the specific identification request, or without mandating the provider as a third party under margin no. 51.

Do clients onboarded before 1 November 2026 have to be identified again?

The revised circular contains no provision requiring relationships opened under the 2021 version to be re-identified. Margin no. 54 deals only with technical adjustments to the QES route. Ongoing due diligence on existing clients is governed separately by the AMLA and AMLO-FINMA.

If a legal entity’s representative is identified by e-ID under margin no. 43.1, is the transfer from the entity’s own account under margin no. 43 still needed?

The circular does not answer this directly. Margin no. 43.1 is worded as an alternative to the margin no. 32 identification of the individuals acting for the entity, while margin no. 43 requires a payment from an account in the entity’s name and was not changed. Read literally, margin no. 43.1 replaces only the identification step, so the margin no. 43 transfer and the margin no. 44 extract and power of attorney stay in the file. That is my interpretation; an intermediary relying on a different reading should record its reasoning.

Does the revised circular bind an intermediary affiliated with a self-regulatory organisation?

Margin no. 2 applies the circular directly only to intermediaries under Article 2 paragraph 2 letters a to d quater AMLA. Whether its content reaches an SRO member depends on that SRO’s regulations: margin no. 4 provides that references to the circular in SRO regulations become valid when the circular enters into force, and that SRO rules differing from it go through the regular approval process.

Can a QR code be checked by eye, or does it have to be read by a machine?

By machine. Margin no. 14 requires the intermediary to use a machine to read and decrypt the information in the MRZ or QR code during video identification, and margin no. 32 requires technology that at least permits the MRZ or QR code to be read and decrypted in the online copy route. The decrypted data then has to be matched against the rest of the document and the data the client entered.

Related Articles

• FINMA Circular 2017/6 Consultation: Direct Transmission Without a List: FINMA’s parallel circular revision on sending non-public information directly to foreign authorities after the Article 42c FINMASA amendment.
• FINMA Small Banks Regime: Where Proportionality Stops: which prudential requirements the Swiss small banks regime relaxes and which AML and conduct duties it leaves in place.
• FATF Fraud Roadmap 2026-2028: Fraud as a Core AML Risk: the FATF’s plan to bring fraud into AML/CFT risk assessment and suspicious transaction reporting.
• AMLA Final RTS: CDD Data, Linked Transactions and Group-Wide Rules: the EU customer due diligence standards, including electronic identification attributes, for groups with EU obliged entities.

Key Takeaways

• Directive update due by 1 November 2026: re-point onboarding procedures to the revised margin numbers, starting with 2, 33, 37.1 and 39 and the new 43.1, 44.1 to 44.4 and 54.
• Payment operations, from 1 November 2026: a margin no. 33 payment only counts if the sending institution is itself a qualifying bank, a category that includes persons under Article 1b of the Banking Act.
• QES onboarding, within one year of 1 November 2026: the flow needs an address step under margin nos. 34 to 37.1 and a liveness step tied to the identification request.
• e-ID onboarding: build to margin nos. 44.1 to 44.4, go live only after the federal e-ID launch, and keep the address check in the design.
• Accepted-document list: QR-only documents are allowed but optional, and machine reading plus security-feature checks apply to them as to MRZ documents.
• Out of bounds under the circular: eIDAS credentials, non-QES signatures and the e-ID inside a video identification session.
• Identification vendors: margin no. 51 keeps the verification duty with the intermediary, so check the provider’s service description and file layout against the new liveness, address and documentation steps.

Sources and References

• FINMA, press release “FINMA adopts partially revised Circular 2016/7 ‘Video and online identification'” (8 October 2026): finma.ch
• FINMA Circular 2016/7 “Video and online identification”, version adopted 23 September 2026, valid from 1 November 2026 (English): PDF
• FINMA Circular 2016/7 “Video and online identification”, version last amended 6 May 2021 (English): PDF
• FINMA, “Teilrevision des Rundschreibens 2016/7 ‘Video- und Online-Identifizierung’: Erlaeuterungen” (explanatory report, 23 September 2026, German): PDF
• FINMA, “Rundschreiben 2016/7 ‘Video- und Online-Identifizierung’: Teilrevision. Bericht ueber die Ergebnisse der Anhoerung vom 16. Dezember 2025 bis 27. Februar 2026” (consultation report, 23 September 2026, German): PDF
• FINMA, press release opening the consultation on the partial revision of Circular 2016/7 (16 December 2025): finma.ch
• FINMA, press release on Guidance 02/2026 on managing digital fraud risks (9 April 2026): finma.ch
• Federal Department of Justice and Police, “Neuer Zeitplan fuer die Einfuehrung der E-ID und der Vertrauensinfrastruktur” (30 June 2026, German): ejpd.admin.ch
• Federal Office of Justice, “Staatliche E-ID” project page (German): bj.admin.ch
• FINMA Anti-Money Laundering Ordinance of 3 June 2015 (AMLO-FINMA; SR 955.033.0), cited as quoted in margin nos. 1, 3, 31.2, 40 to 41 and the margin no. 53 table of the revised circular listed above
• Regulation (EU) No 910/2014 (eIDAS Regulation), cited as characterised in section 3.3.2 of FINMA’s consultation report listed above
• FINMA, draft amendment of Circular 2016/7 put to consultation (16 December 2025, German): PDF
• Swiss federal acts and ordinances cited as quoted in the revised circular and FINMA’s explanatory report listed above: E-ID Act of 20 December 2024 (BBl 2025 20); Banking Act of 8 November 1934 (SR 952.0); Federal Act of 18 March 2016 on Electronic Signatures (SR 943.03); OFCOM Ordinance of 23 November 2016 on certification services (SR 943.032.1); Gambling Act of 29 September 2017 (SR 935.51); Precious Metals Control Act of 20 June 1933 (SR 941.31)
• Agreement of 13 June 2018 on the Swiss banks’ code of conduct with regard to the exercise of due diligence (CDB 20), Article 9, cited as characterised in footnote 3 of FINMA’s explanatory report listed above
• Federal Act of 10 October 1997 on Combating Money Laundering and Terrorist Financing (Anti-Money Laundering Act, AMLA; SR 955.0): fedlex.admin.ch
• AMLA (EU Authority for Anti-Money Laundering), factsheet on the RTS on customer due diligence under Article 28(1) of Regulation (EU) 2024/1624 (September 2026): PDF

Before 1 November 2026: re-mapping each digital onboarding route

On 1 November 2026 the margin no. 33 origin check, the QR-code permissions, the new address wording and the narrower scope take effect. The QES address and liveness steps follow under the one-year transition, and the e-ID route waits for the federal credential. The artifact to produce before 1 November is a marked-up onboarding directive that assigns every digital route its new margin numbers and a dated owner for the QES change. The decision that cannot wait for the e-ID is whether the margin no. 33 control in production actually identifies the institution that sent the payment.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.