FINMA’s digital identification update: what changes in November

The brief

FINMA has finalised changes to its video and online identification circular, effective 1 November 2026. They introduce additional digital identification options, including Switzerland’s state e-ID. A specific transition for qualified electronic signature processes means the implementation timetable needs closer reading than the headline date. FINMA’s announcement and revised circular set out the changes.

Our practical conclusion is to record which identification route was used, which checks were completed and which remain outstanding. A successful identity check should also stay distinct from authority to act for a company or approve a particular instruction. Those are separate questions. Firms reviewing onboarding should test whether a colleague can reconstruct each decision from the retained evidence.

The full record

FINMA announced the final revision on 8 October. The changes permit identification using the new Swiss state e-ID, recognise QR codes on identity documents alongside machine-readable zones, and expand ways of verifying residence digitally. They also address liveness checks: establishing that the person is present during identification. Source: FINMA, 8 October 2026.

Read the transition at process level

The revised circular takes effect on 1 November 2026. Paragraph 54 gives one year from entry into force for necessary technical adjustments to residence verification and liveness checks in the qualified electronic signature route under paragraph 39. This is a specific transition, not a general postponement of the circular. The e-ID route has its own verification and documentation provisions in paragraphs 44.1–44.4. Source: revised Circular 2016/7.

Our analysis: preserve the reason for acceptance

Start with a process map rather than a list of approved technologies. For each identification route, show the evidence received, the checks performed, the result and the person or system that accepted it. If a provider returns only a green status, establish what that status means and how the underlying evidence can be retrieved when needed.

Keep identity, representation and transaction approval separate. For example, identifying a finance director does not itself answer whether that person can bind a company to a new mandate. The working record should connect the identified person to the relevant authority and, later, to the exact instruction being accepted. This is our proposed design principle, not an additional rule announced by FINMA.

A useful acceptance test

Give a reviewer a fictional onboarding file with a passed identity check but a missing authority document. Ask them to explain whether the file is ready for the intended action. The test should fail if a general “verified” label conceals the unresolved question.

Also test a change of identification provider. Can a later reviewer still understand an earlier result, its date and any exception? Restrict access to retained identity evidence and decide what genuinely needs to be kept; a useful decision record does not require copying every sensitive document into every communication.

The immediate task is to map the revised provisions to each affected workflow and its implementation date. The enduring task is to make the basis for acceptance recoverable without relying on the original operator’s memory.

We checked FINMA’s final announcement and the relevant identification and transition provisions of the revised circular. This article focuses on digital onboarding; application depends on the intermediary and identification route. The workflow and test are editorial analysis, not a compliance assessment or a benchmark already performed.

1. FINMA final revision announcement, 8 October 2026
2. Revised Circular 2016/7, especially paragraphs 39, 44.1–44.4 and 54