Digital Client Identification: Remote KYC & eIDAS 2.0 for Professionals
Can you do KYC remotely? What does Greek and European law permit for digital identification? Which technologies are acceptable under eIDAS 2.0?
What Does the Law Permit for Digital Identification?
L.4557/2018 (Article 11) provides for the possibility of "non-face-to-face" identification, but under specific conditions: • The measures are (as far as possible) equivalent to those of in-person verification • There are additional compensating measures (e.g. first payment from a bank account in the client's name) • The process is fully documented Digital identification is permitted, but the professional bears the burden of proving that the process was adequate.
eIDAS 2.0: What Changes for Accountants and Lawyers
Regulation eIDAS 2.0 (EU 2024/1183) introduces the European Digital Identity Wallet (EUDI Wallet), which: • Will allow every EU citizen to identify themselves digitally at a high level of assurance • Will prove identity, address and professional qualifications electronically • Will be accepted for KYC as a "qualified electronic attestation" For professionals: from 2026, acceptance of the EUDI Wallet as an identification method is expected to be explicitly permitted in national legislation. Greece is already implementing the Digital Wallet through gov.gr.
Video KYC: Is It Accepted in Greece?
Video KYC (identification via video call) is becoming increasingly widespread. In Greece: Legal basis: Permitted under L.4557/2018 Article 11, but there is no yet explicit guidance from supervisory authorities on exactly how it must be conducted. Recommended compensating measures: • Live video call (not a recorded video) • Real-time document authenticity check (liveness check) • Record of the call (with the client's consent, under GDPR) • Confirmation via first payment from a bank account in the client's name
When Digital Identification Is NOT Acceptable
Digital identification is NOT appropriate for: • EDD clients (high-risk, PEPs): For these, in-person verification or an equivalently rigorous process with biometric verification is recommended. • Anonymous transactions: If identity cannot be verified digitally with certainty, the transaction must not proceed. • Countries without reliable electronic ID: If the client does not have an accepted digital ID (e.g. non-EU countries without a mutual recognition agreement). Practical recommendation: If in doubt about the equivalence of digital versus physical identification, prefer physical — the legal liability is yours if something goes wrong.