In recent years, the significant digitalisation of the financial sector – particularly in the context of the Covid-19 crisis – has led to an increase in remote relationships between financial players and their customers. This development has necessarily led to a growing demand for solutions allowing the onboarding of remote customers. In this context, the European Banking Authority (EBA) has launched a public consultation on its draft guidelines for the use of remote customer integration solutions. 

In the crypto-asset sector, the needs for remote client onboarding solutions are particularly important. Indeed, most business models in the crypto sector establish relationships without physical contact with their customers. For these reasons, Adan welcomes EBA’s intention to issue guidelines to harmonise the requirements for these onboarding solutions at EU level.    However, in this document, Adan wished to draw the attention of the EBA to the necessity to go further on the requirements to be implemented with regard to these onboarding solutions, on the one hand, to ensure a perfectly harmonised framework, and on the other hand to limit the potential vulnerabilities that some solutions could have, which could lead to an inoperative identity verification system and facilitate fraud. 

To this end, Adan proposes several recommendations: 

  • Strengthening identity proofing requirements: The requirements set out in these guidelines are not sufficient and will not put any constraints on the actors. In our view, this will not facilitate the harmonisation of the framework for these onboarding solutions. According to Adan, the EBA guidelines should be further developed regarding remote identity verification and possibly inspired by other comprehensive sources on the topic to ensure a better level of harmonisation at EU level (ETSI TS 119 461, ENISA risk assessment identity proofing, PVID certification by ANSSI). 


  • These guidelines are an opportunity to establish an EU certification regime for remote onboarding solutions. Adan proposes to create a European Union-level regulation for remote identity verification providers and to oblige actors wishing to offer remote onboarding solutions to comply with this regulation and in particular, with the ETSI TS 119-461 standard. 


Adan is available for any question on this paper.