Swiss digital onboarding rules add liveness checks as AI fraud pressure rises

Revised Swiss rules for video and online identification entered into force on 1 November, allowing the country's electronic identity credential to support customer onboarding under anti-money-laundering rules. FINMA's updated Circular 2016/7 also treats identification documents with a QR code, such as a Swiss driving licence, as equivalent to documents with a machine-readable zone.

The most significant change for fraud teams is a requirement to introduce liveness detection as an additional security measure for online identification. FINMA explicitly linked the measure to growing risks from new technologies, particularly artificial intelligence. The circular also permits digital processes that reliably connect a contracting party and its infrastructure to a place of residence.

The revision illustrates a wider regulatory shift: digital identity programmes are being asked to improve convenience while proving resistance to synthetic media and replay attacks. Liveness is useful, but it is not a complete defence. Institutions still need layered document validation, device and network signals, challenge design, monitoring for presentation and injection attacks, and a route to human review. The operational question is how those controls work together without excluding legitimate customers or creating a new biometric data risk.

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