On 9 March 2022, the German Banking Industry Committee (GBIC) commented on the public consultation of the European Banking Authoritys (EBA) Draft Guidelines on the use of Remote Customer Onboarding Solutions. There are fundamental concerns as to whether the proposed requirements for financial institutions can achieve the desired harmonisation of know-your-customer (KYC) requirements and defragmentation of the Digital Single Market for financial services. Rather, the guidelines could further increase the existing fragmentation through different application by each individual institution and create legal uncertainty, not least due to the continued lack of uniform technical standards and the lack of demarcation from state-regulated procedures.
