KYC portability in the age of eIDAS 2.0

The report I was instructed to prepare on KYC portability has now been published by the European Commission - see link below.

The report analyses cross-border KCY data portability within the context of the 2021 eIDAS 2.0 proposal and contemplated AML regulation – initiatives expected to have a major impact on banking services with the deployment of digital identity wallets and CDD data harmonisation. It reviews the types of KYC attributes and discusses how European financial institutions can act as KYC data providers and receivers. In cooperation with the eWallet Network, it presents an Open Wallet proposal meeting eIDAS 2.0 requirements, including offline functionalities for payment authorisation and qualified electronic signature, as well as offering robust privacy protection. The report also compares traditional bank-led KYC portability scenarios and the emerging user-centric self-custody solution implied by digital identity wallets. It considers governance matters for KYC data exchanges, including economic models, scheme arrangements and liability allocation provisions and sets out a number of practical recommendations aiming to offer scalability, consistency with AML/CFT requirements as well as process mutualisation solutions for the banking industry.??

The report can be downloaded here.