FINMA Circular 2016/7: Key Changes
What the FINMA 2026 revision means for digital onboarding
The planned revision of FINMA Circular 2016/7 brings greater clarity to digital identification and signing processes. It expands the available technical options, specifies the requirements for residence verification, and explicitly anchors eID and qualified electronic signatures (QES) in the regulatory framework. At the same time, expectations regarding clear structuring and consistent implementation of digital processes are increasing.
Who is affected by the changes?
The revision is particularly relevant for:
- Banks and financial intermediaries
- Providers of digital onboarding and KYC processes
- Organizations using qualified electronic signatures (QES)
- Teams evaluating or preparing eID-based identification
In short: all organizations that view identification and contract execution not as isolated cases, but as scalable digital processes.
What changes in practice?
Greater technological openness for identity documents:
In addition to identity documents with a machine-readable zone (MRZ), documents with QR codes will also be permitted for video and online identification. This allows the use of additional identity documents that rely exclusively on QR codes, increasing flexibility in document selection and enabling more modern onboarding flows.
Residence verification becomes mandatory:
Residence verification is now clearly defined and will be mandatory for all correspondence openings—both in the context of qualified electronic signatures and eID-based procedures.
Permitted methods include, among others:
✔ Matching against official postal and address databases
✔ Register checks
✔ Document-based evidence such as utility bills
For eID procedures, no selfie is required; however, residence verification is mandatory. In practice, residence thus becomes a distinct and plannable process step. This is particularly relevant for organizations that perform identification and signing at scale and aim to avoid manual exceptions.
QES explicitly permitted for business customers:
The revision explicitly confirms that qualified electronic signatures may also be used for business accounts. This provides legal certainty for digital B2B processes—for example, company account openings, signing and representation rules, or contract execution involving multiple parties.
Clarification rather than realignment
The revision does not introduce fundamental changes. The focus lies on maintaining and harmonizing existing rules, as well as targeted additions—particularly in the area of eID. The requirements become clearer, more consistent, and better aligned with today’s digital processes.
The Swiss e-ID as an additional identification channel
The Swiss e-ID is approved as a means of online identification. It therefore offers a simple and standardized path to digital correspondence opening. For existing onboarding processes, this does not replace established procedures, but adds an additional, regulatorily anchored option.
Looking ahead: residence as a modular process component
Regulatory requirements and a strong user experience can be combined if residence verification is designed as a modular step, for example:
- Primarily via matching with postal and address databases
- As a fallback, via an automated utility-bill scan with structured data extraction
This keeps the process lean and regulatorily sound—without unnecessary complexity for users.
Conclusion
The FINMA 2026 revision makes digital onboarding more flexible while also more structured. Organizations that implement the new requirements consistently at an early stage will achieve not only regulatory certainty, but also better user experiences and robust, future-proof processes.
Questions about implementing the FINMA revision?
Whether eID or residence verification: we support you in integrating FINMA’s new requirements into your onboarding processes in a compliant, practical, and user-friendly way.
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