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Regulators Clear Digital IDs for Bank Onboarding

On 8 September 2026, five federal agencies confirmed that banks may accept state-issued mobile driver's licenses and other verifiable digital credentials to verify customer identity under the CIP rule — an option, not a mandate.

Why It Matters

OCC Bulletin 2026-44, issued jointly by the OCC, FinCEN, the Federal Reserve, the FDIC and the NCUA, answers FAQs on the treatment of verifiable digital credentials (VDCs) — including state-issued mobile driver's licenses (mDLs) — under the Customer Identification Program rule at 31 CFR 1020.220. An unexpired government-issued digital credential can count as “government-issued identification” where it evidences nationality or residence, includes a photograph or similar safeguard, and the institution's written CIP program permits it.

The guidance enables but does not require digital onboarding. It adds no new supervisory expectation and changes no Bank Secrecy Act duty; institutions still own the technical verification, fraud detection, and the “reasonable belief” standard. For compliance teams, the immediate task is a documented policy decision, not a system build.

Action Items

  1. Set your CIP policy — Decide whether to permit mDLs/VDCs in your written CIP program; document the acceptance criteria and update onboarding procedures.

  2. Scope the technical build — Assess the infrastructure needed to cryptographically verify VDCs (issuer signature, device binding, activation factor) before relying on them.

  3. Protect fraud controls — Confirm that accepting digital credentials does not weaken fraud detection or the “reasonable belief” standard; retain documentary and non-documentary fallback methods.

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