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EBA remote onboarding
Remote onboarding under the EBA guidelines
The EBA guidelines on remote customer onboarding set how banks and other financial firms verify a client they never meet. Trust Circle covers the identity part: a document check, a liveness check and a face match, done by a qualified trust service provider on the EU Trusted List.
265+ ID documents from 50+ nationalities · Verified once, valid for 2 years
EBA/GL/2022/15 PARAS 33 TO 45
Key dates
Three dates that matter for your institution
The guidelines apply to credit and financial institutions in every country whose supervisor complies with them, including Sweden, the Netherlands, Germany and France.
From 10 July 2027, the EU AML Regulation and AMLA's rules take over remote verification. Trust Circle and AMLR →
What the guidelines ask
You own the onboarding process. A provider can carry the identity check.
What the guidelines ask of your institution
- Write remote onboarding policies, approved by management
paras 9–12 - Assess the solution before you use it
paras 13–17 - Monitor it once it runs, and fix what goes wrong
paras 18–22 - Check that the ID document is genuine and unaltered
paras 33–37 - Match the person to the document, with liveness detection
paras 38–41 - Keep control when you rely on or outsource to a provider
paras 46–49
The eIDAS route in the guidelines
Some requirements count as met.
Where you use eID at level substantial or high, or relevant qualified trust services, several assessment, capture and matching requirements are deemed met. paras 15, 25, 45
Whether a service counts is your call.
You still assess whether a trust service fits your process, and how it handles impersonation and expired or stolen documents. para 54
Where the guidelines apply
Supervisors that follow the guidelines
The guidelines, paragraph by paragraph
Where Trust Circle covers the identity steps
Paragraph numbers refer to EBA/GL/2022/15. Your institution's policies, assessments and onboarding decisions remain your own.
After July 2027
What replaces the guidelines
01
Their legal basis ends.
The guidelines rest on the 2015 AML directive, which is repealed from 10 July 2027. The EU AML Regulation applies directly from that date.
02
eID becomes the default.
AMLA's final draft rules of 30 Sep 2026 make eID and relevant qualified trust services the default way to verify a client remotely. Document and selfie checks need a recorded reason.
03
Some decisions never move.
Under AMLR Art 18(3), the client's risk profile and the decision to onboard stay with your institution, whoever runs the checks.
Where Trust Circle stands: ZealiD is a Qualified Trust Service Provider on the EU Trusted List. We'll publish how Trust Circle maps to AMLA's final rules once the Commission adopts them.
AMLR for firms that onboard clients →What stays with your institution
Policy and assessment
Writing and approving your remote onboarding policy, and assessing the risk of the solution for your business, are yours.
Screening and the decision
Sanctions and PEP screening against live lists, the risk profile and the decision to onboard stay with you.
Legal entities and owners
Trust Circle verifies natural persons. Checks on legal entities and their beneficial owners follow your own process.
Trusted by banks, law firms and platforms
We are building a future-proof bank, digital by design… Our business clients can now sign their credit and guarantee documentation digitally with ZealID, a provider of qualified electronic signatures and a partner of ABN AMRO.
Meets German AML rules (GwG)
DocuSign resells ZealiD's qualified signature, with ID document data, to its customers in German finance for remote identification.
Read the case study →Qualified Trust Service Provider
Check us on the EU Trusted List, not on our word
- Listed on the EU Trusted List (Sweden): qualified certificates for electronic signatures, qualified timestamps and remote qualified signature creation
- Supervised by PTS, the Swedish Post and Telecom Authority
- Audited every year by TÜViT
- Identity checks certified against ETSI TS 119 461
- Documents stored in Stockholm, EU
ZealiD AB
QUALIFIED TRUST SERVICE PROVIDER
LISTED SERVICES · SWEDEN
Pricing
For teams and for institutions
Professional + KYC add-on
€119.20a month, billed yearly
+ €100 a month for KYC
- Up to 10 users
- 75 QES a month
- KYC questionnaires, risk scoring and automatic renewal
Enterprise and API
Custom
- 11 or more users
- Identity verification and qualified signatures in your own onboarding flow
- Custom contract
Identity verification is included in every plan, with no fee per check. See all plans →
Put a qualified trust service behind every remote check
Verify clients on their phone, keep the result for 2 years, and sign with the same identity.
Questions about the EBA guidelines
Who do the EBA remote onboarding guidelines apply to?
Credit and financial institutions under the EU AML directive, in countries whose supervisor complies with the guidelines. They have applied since 2 October 2023.
Do they apply to law firms or accountants?
No. They are addressed to credit and financial institutions. Law firms and accountants follow their national AML rules today and the EU AML Regulation from 10 July 2027.
Is Trust Circle EBA approved?
The EBA does not approve vendors. The guidelines bind institutions, which assess each solution themselves. ZealiD gives you its certificates, practice statements and terms for that assessment.
Does a qualified trust service shortcut the requirements?
Paragraphs 15, 25 and 45 treat several requirements as met where you use eID at level substantial or high, or relevant qualified trust services. Whether a given service counts is your institution's assessment.
What happens to the guidelines in July 2027?
Their legal basis, the 2015 AML directive, is repealed from 10 July 2027. Remote verification then follows the EU AML Regulation and AMLA's rules.
Does Trust Circle screen clients against sanctions lists?
No. Sanctions and PEP screening against live lists runs in your screening tool. Trust Circle's KYC questionnaire collects the client's declarations and a staff-only record of your screening result.
Can we build the check into our own onboarding flow?
Yes, through the ZealiD API on an Enterprise contract. Read the API docs.
Does identity verification cost extra?
No. It's included in every plan, with no fee per check.