KYC (Know Your Customer)

Why it matters for PSPs and EMIs

Every payment or e-money account has people behind it: consumers, sole traders, and the directors, representatives and beneficial owners of business customers. Their identities must be established before the relationship starts. For remote, digital onboarding, the quality of the identity evidence is what a supervisor examines first.

What the law says

• Identify and verify. AMLR Art. 20(1)(a) requires the customer to be identified and its identity verified; Art. 20(1)(i) extends this to anyone acting on the customer's behalf.

• What to collect for a natural person. AMLR Art. 22(1)(a): all names and surnames; place and full date of birth; nationalities (or statelessness or protection status) and the national identification number where applicable; the usual place of residence, and where available the tax identification number.

• How to verify. AMLR Art. 22(6): either an identity document, passport or equivalent, together with information from reliable and independent sources where relevant; or electronic identification means meeting the eIDAS assurance levels "substantial" or "high", and relevant qualified trust services.

• When. AMLR Art. 23(1): before the relationship is established or the occasional transaction is carried out, with limited exceptions for lower-risk situations.

• Detail to come. The information to be collected and the reliable and independent sources that may be used will be specified in regulatory technical standards that AMLA drafts and the Commission adopts (AMLR Art. 28(1)(a) and (d), and 28(4)).

• Until 10 July 2027. The equivalent duties come from national law transposing Directive (EU) 2015/849 (Arts. 13 and 14). For remote onboarding, see EBA Guidelines EBA/GL/2022/15.

• International standard. FATF Recommendation 10.