Art. 7 Verification measures conducted on a non-face-to-face basis | RTS on customer due diligence | AML

This article builds directly on Article 6, which covers face-to-face identity verification, by addressing the non-face-to-face equivalent.

It establishes a clear hierarchy of preferred methods for remotely verifying a natural person's identity.

The first preference is for electronic identification means meeting 'substantial' or 'high' assurance levels under Regulation (EU) No 910/2014.

Only where this is unavailable or cannot reasonably be provided may obliged entities fall back on other remote document-based solutions, which must then satisfy a detailed set of technical and procedural safeguards covering image quality, communication integrity, document validity, and secure record retention.

Important points:

Use electronic identification means at 'substantial' or 'high' assurance levels as the primary method for non-face-to-face identity verification.
Where the primary method is unavailable, use remote document-based solutions that meet specific safeguards, including controls to match the presenter to the document, confidentiality of communications, and secure time-stamped storage of records.
Be prepared to demonstrate to your competent authority that any remote solution used complies with this article, and justify why the preferred electronic identification method could not be used.

1. To comply with the verification requirements pursuant to Article 22(6) of Regulation (EU) 2024/1624 in a non-face-to-face situation, obliged entities shall use electronic identification means that meet the requirements of Regulation (EU) No 910/2014 with regard to the assurance levels ‘substantial’ or ‘high’, or relevant qualified trust services as set out in that Regulation.
1. In cases where the solution described in paragraph 1 is not available, or cannot reasonably be expected to be provided, obliged entities shall obtain the natural person’s identity document, passport or equivalent using remote solutions that meet the conditions set out in paragraphs 3 and 4.
1. Obliged entities shall ensure that the solution described in paragraph 2 uses reliable and independent information sources and includes the following safeguards regarding the quality and accuracy of the data and documents to be verified:
  1. controls to ensure that the natural person presenting the customer’s identity document, passport or equivalent is the person on the picture of the document;
  2. the integrity and confidentiality of the communication through the solution are ensured;
  3. any images, video, sound and/or data processed through the solution are captured in a readable format and with sufficient quality so that the natural person is unambiguously recognisable;
  4. where applicable, the identification process does not continue if technical shortcomings or unexpected connection interruptions are detected or there are any doubts regarding the identity of the natural person;
  5. the information, documents and data verified through the remote solution are valid and up-to-date and copies are retained, time-stamped and stored securely by the obliged entity. The content of stored records, including images, videos, sound and data shall be available in a readable format and allow for ex-post verifications.
1. Obliged entities using remote solutions shall be able to demonstrate to their competent authority that the remote verification solutions they use comply with the requirements of this Article and they shall also be able to justify why the customer could not be verified through the means referred to under Article 22(6) of Regulation (EU)2024/1624.