Step 1
Consent and start
The customer opens the widget on the website, in the app or by a link and gives consent to the processing of personal data — the consent text is yours, and it is configured in the editor.
Remote identification of customers
Remote identification is establishing a customer's identity without a visit to the office, as Federal Law No. 115-FZ requires: through ESIA and the Unified Biometric System (EBS), in the simplified procedure or on a bank's instruction. Work out which route is available to your organisation — and NeuroVision will take care of the document, database checks, liveness and the link to the EBS.
EBS integration in your environment Lists and sanctions — in the same session Data stays on servers in Russia
Remote identification: what it is under the law and how it differs from verification
The law sets the method, the service provides the tools
The method of remote identification is chosen by the type of activity and the operation. The method determines what information to collect and how to confirm it.
- 01
Identification is a term of Federal Law No. 115-FZ, verification is not
Identification is establishing information about a customer and confirming it: full name, citizenship, date of birth, document details, address. It must be carried out by the organisations listed in Art. 5 of Federal Law No. 115-FZ before the customer is accepted for service. Remote identity verification is a broader concept: it is the name for any online check that a person is who they claim to be. More about these terms — in the article "KYC verification: how customer identification works".
- 02
"Remote" means "without personal presence"
The law does not use the word "remote": it speaks of identification "without the customer's personal presence". Electronic identification of a customer is lawful only by the methods expressly named in Art. 7 of Federal Law No. 115-FZ — there are four, discussed below.
- 03
Full and simplified — different scopes
Full identification establishes the whole set of information, including address and citizenship. Simplified identification covers the full name and the passport series and number, confirmed by one of the three methods in the law. The simplified procedure is allowed only for the operations in cl. 1.11 of Art. 7.
- 04
The obligation stays with your organisation
The service does not replace you as the identifying organisation: identification is carried out by the organisation under Art. 5 of Federal Law No. 115-FZ itself, and it can be delegated only to persons expressly named in the law. NeuroVision provides the tools — the document, checks, liveness, the EBS. How this looks in online customer onboarding — on the page about customer onboarding.
- 4 methods without personal presence in Art. 7 of Federal Law No. 115-FZ
- 5 years keep the information after the end of the relationship
- 1 session document, checks and liveness in a single customer visit
Four ways to identify a customer without a visit to the office
Remote identification of an individual under Federal Law No. 115-FZ is possible in four ways. Which of them are available to you depends on who you are — a bank, a non-bank financial institution, another organisation under Art. 5 of the law — and what operation the customer performs.
- Banks and other organisations supervised by the Bank of Russia may identify an individual customer and the head of a legal-entity customer without personal presence through ESIA and the Unified Biometric System (cl. 5.8 of Art. 7 of Federal Law No. 115-FZ, Art. 9 of Federal Law No. 572-FZ)
- Conditions: the customer is not on the list of persons involved in extremism and terrorism or on the UN Security Council lists, there is no court decision to freeze funds and suspend transactions in respect of them, and there is no suspicion of money laundering (cl. 5.8 of Art. 7)
- A bank with a universal licence that opens accounts and issues loans through a website or an app must give customers this route (cl. 5.8-1 of Art. 7)
- The customer provides the full name, the passport series and number, and also the SNILS, INN, compulsory medical insurance policy number or driving licence number, and a mobile phone number; the organisation confirms that the information matches in state information systems, and a code sent to the phone (subcl. 2 of cl. 1.12, cl. 1.13 of Art. 7)
- Another method is the customer's authorisation in ESIA, giving the full name and SNILS (subcl. 3 of cl. 1.12 of Art. 7)
- Works only for the operations in cl. 1.11: transfers without opening an account and electronic money up to 100,000 ₽, insurance, brokerage contracts, non-state pension funds, investment platforms and others
- A bank may delegate identification to a telecom operator, a postal service organisation or an accredited certification authority (cl. 1.5 of Art. 7)
- Microfinance organisations, pawnshops, insurance brokers, non-state pension funds, leasing and factoring companies, realtors, jewellers — only to a credit institution (cl. 1.5-2, 1.5-9, 1.5-10 of Art. 7)
- The delegating organisation remains responsible for the result: the requirements for the contract and liability — cl. 1.6–1.9 of Art. 7
- Marketplaces, car sharing, rental and hiring services, if they are not covered by Art. 5 of Federal Law No. 115-FZ, check the customer under their own rules and contract; this is verification, not identification under Federal Law No. 115-FZ
- For intermediary digital platforms, from 1 October 2026 Federal Law No. 289-FZ "On the Platform Economy" applies, with its own rules for checking partners
- Separate regimes: certification authorities when issuing a qualified certificate (Art. 18 of Federal Law No. 63-FZ) and mobile operators — they have their own rules
- This is a guide for a conversation with a lawyer, not a legal opinion. The summary of the rules is simplified; the exact text is in ConsultantPlus. The obligations under Federal Law No. 115-FZ are discussed in the article "Requirements for a KYC provider: what a business must do and what can be bought from a vendor".
Who may identify a customer without personal presence
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Banks
May. Identify through ESIA and the EBS under the conditions of cl. 5.8; in the simplified procedure — for transfers without an account and electronic money up to 100,000 ₽.
Important. Opening an account without personal presence is prohibited, except in cases expressly provided for by law (cl. 5 of Art. 7). -
Microfinance and microcredit companies
May. Remotely — only through ESIA and the EBS, and every online loan must be confirmed by biometric authentication.
May not. Issue a loan under simplified identification: for microfinance companies — from 1 March 2026, for microcredit companies — from 1 March 2027 (cl. 1.12-1, 5.8-2 of Art. 7; Art. 16 of Federal Law No. 41-FZ). -
Insurers, brokers, non-state pension funds, investment platforms
May. Simplified identification for the contracts in cl. 1.11; life insurance — if premiums do not exceed 40,000 ₽ (cl. 1.12-2).
May not. Brokerage and trust management contracts with transactions in digital currencies may be concluded in the simplified way (cl. 1.12-5, from 2026). -
Payment services and electronic money
May. Simplified identification for transfers without opening an account and for an electronic means of payment up to 100,000 ₽ (cl. 1.11).
Important. Identification may be delegated to a third-party organisation by a bank, not by the service itself: to a telecom operator, the post or an accredited certification authority (cl. 1.5). -
Leasing, factoring, realtors, pawnshops, jewellers
May. Delegate identification to a credit institution under a contract (cl. 1.5-9, 1.5-10).
Important. Organisations not supervised by the Bank of Russia have no right to the EBS route under cl. 5.8; how to accept customers remotely with their own resources is a question for a lawyer. -
Marketplaces, car sharing, services outside Federal Law No. 115-FZ
May. Check the customer under your own rules: document, liveness, databases.
Important. This is verification, not identification under Federal Law No. 115-FZ; collecting biometrics for identification in your own systems is prohibited (Part 1 of Art. 15 of Federal Law No. 572-FZ).
Remote customer identification is not equally available to everyone. Below are six typical cases; find yours and check the conclusion with a lawyer.
The cards are a guide, not an opinion: every industry has exceptions by amounts and types of contracts. How this works in industries — banks, Microfinance, other financial organisations.
Simplified identification online: what information is needed and how to confirm it
Online identification of a customer in the simplified procedure under subcl. 2 of cl. 1.12 is built on information that the customer provides themselves and on its confirmation. Here is what to collect and how NeuroVision helps at each step. Catalogue of database checks · Russian passport recognition
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Full name and passport without manual entry
The customer photographs the passport, the fields are recognised automatically, and the check sums of the machine-readable zone are verified. Anti-fraud screens out a photo of a screen, a printout, a photocopy, a pasted-in photo and traces of a graphics editor.
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The passport is valid
A check of the passport's validity against the Ministry of Internal Affairs database — in the same session, 5 ₽. An invalid passport stops the process before the rest of the information is checked.
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INN by passport
If the customer does not remember their INN, it can be obtained from the passport data and compared with what they entered — 5 ₽. One of the identifiers the law accepts for the simplified procedure.
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Match of full name and SNILS
A check that the SNILS belongs to this particular person — 5 ₽. The second identifier option under subcl. 2 of cl. 1.12.
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Driving licence
A driving licence is recognised as an additional document of the session (10 ₽), the reverse side is free. The licence number is another permitted identifier; a check for deprivation of driving rights — 5 ₽.
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Phone and confirmation code
The phone number and the confirmation code are on your side: the law requires the customer to confirm receipt of information at the number they have given (cl. 1.13). NeuroVision passes the recognised data and check results for this step to your system.
How remote identification works with NeuroVision
One customer is one KYC session. You set the sequence of steps in the KYC editor for the chosen identification method.
Step 2
Document and anti-fraud
The customer photographs the passport with a phone camera. The fields are recognised, the machine-readable zone is checked, and signs of forgery are recorded. Up to 6 free attempts per step.
Step 3
Liveness and face comparison
If the scenario requires confirming live presence, the customer passes liveness, and the face is compared with the photo in the passport. How it works — on the page about liveness.
Step 4
Lists and databases
The passport data goes into the checks: passport validity, INN, SNILS, the list of terrorists and extremists, sanctions lists. The results arrive as they are ready.
Step 5
EBS — through your environment
If your organisation may identify through ESIA and the EBS, NeuroVision is built into this route: the EBS integration is connected in your environment, and the document and database checks run in the same session.
Step 6
Result and customer profile
Your system receives the session result, the recognised fields and the check results and fills in the customer profile. An employee sees everything in the dashboard and can change the status manually.
Customer profile after identification: what to record and how long to keep it
Customer identification ends not with a check but with a record: the information goes into the customer profile, and is stored and updated under the rules of Federal Law No. 115-FZ.
- Recognise a passport
Full identification of an individual
The whole set of information on accepting a customer.
Customer information
- Full name
- citizenship
- date of birth
- details of the identity document
Additionally
- a document confirming the right of stay for a foreigner
- registration or stay address
- INN — if available, and mandatory for contracts with digital currencies
- Database checks
Simplified identification
A short set for the operations in cl. 1.11.
What to establish
- Full name
- passport series and number
- phone number
How it was confirmed
- SNILS, INN, compulsory medical insurance policy or driving licence — the identifier
- confirmation result
- View the dashboard
Storage and updating
Deadlines under Federal Law No. 115-FZ.
Storage
- information and documents — at least 5 years after the end of the relationship with the customer
Updating
- low-risk customers — at least once every three years, others — at least once a year
- in case of doubt — within 7 working days
In the NeuroVision dashboard every session has a photo, recognised fields, check results and status history; reports are exported to CSV. Original images are stored for 3 months free of charge, then at the tariff rate.
Restrictions: biometrics, consent and bans on the simplified procedure
Remote identification runs into several hard rules. They should be taken into account before you build a scenario.
- It is prohibited to process, collect and store biometric data for identification in organisations' systems — except collection for placement in the EBS (subcl. 1 of Part 1 of Art. 15 of Federal Law No. 572-FZ)
- Identification by biometrics goes through the EBS: the organisation receives the degree of match of the face to the EBS vectors and information from ESIA (Part 1 of Art. 9 of Federal Law No. 572-FZ)
- Cross-border transfer of biometrics during identification is prohibited (Part 21 of Art. 3 of Federal Law No. 572-FZ); NeuroVision processes data in Russia or in your environment
- Consent to the processing of personal data — under Art. 9 of Federal Law No. 152-FZ; to biometrics — in writing or as an electronic document with a signature (Part 1 of Art. 11 of Federal Law No. 152-FZ, Part 3 of Art. 9 of Federal Law No. 572-FZ)
- The consent text and the screen for it are configured in the NeuroVision widget
- Giving biometrics may not be mandatory, and refusing to do so may not be a reason to refuse a service or to refuse to accept a customer for service (Parts 11 and 13 of Art. 3 of Federal Law No. 572-FZ)
- So the customer must have another route: the office, simplified identification or delegation to a bank
- Microfinance organisations may not issue loans under simplified identification: microfinance companies — from 01.03.2026, microcredit companies — from 01.03.2027 (para. 2 of cl. 1.12-1 of Art. 7 of Federal Law No. 115-FZ)
- Simplified identification does not apply to brokerage contracts and trust management with transactions in digital currencies and digital rights (cl. 1.12-5)
- If there are doubts that it is the same customer applying, the organisation carries out identification again under its internal control rules (cl. 5.8 of Art. 7, last paragraph)
- The summary of the rules is simplified; not a legal opinion. On how the EBS works — in the article “The Unified Biometric System”; on the requirements for a provider — "Requirements for a KYC provider".
What NeuroVision takes on in remote identification
The document with no manual entry
16,000+ types, 195+ countries
16,000+ types of documents from 195+ countries and territories, recognition in under a second, document anti-fraud in all packages.
Data for simplified identification
5 ₽ each in the same session
Passport validity, INN from the passport, match of full name and SNILS — 5 ₽ each in the same session.
The conditions of cl. 5.8 under control
Lists and sanctions — before the decision
The list of terrorists and extremists, the OFAC, EU, UK and UN sanctions lists, Rosfinmonitoring lists, the register of foreign agents — before the decision to accept the customer.
Liveness and face comparison
iBeta PAD Level 1–3
Protection against photos, screens, masks and deepfakes (iBeta PAD Level 1–3), comparison of a selfie with the photo in the document. In detail — on the page about verification by passport and selfie.
EBS integration and your environment
Cloud in Russia or on-premises
The link to the EBS in your environment, a cloud in Russia or on-premises installation in Docker containers.
115‑FZ
The obligation to identify is yours. The tools, the checks and the trail of every session are ours.
How much remote identification of one customer costs
You pay for a KYC session — one customer visit with all the steps of the scenario. Repeat capture attempts are not charged.
- Calculate
Document
from 16 ₽ per session
Document recognition, anti-fraud, machine-readable zone check.
- Calculate
Document + liveness
from 29 ₽ per session
Everything from the "Document" package plus a selfie or liveness, face comparison with the document.
- Discuss
Extended
on request
Document, liveness and database checks in one package.
Checks for simplified identification and the conditions of cl. 5.8 — 5 ₽ each: passport validity, INN from the passport, full name and SNILS, the list of terrorists and extremists, sanctions lists. An additional document, for example a driving licence — 10 ₽. International screening — 36 ₽. The cost of querying the EBS is set by its operator (Art. 12 of Federal Law No. 572-FZ) and is not included in the session price. Calculator in the price matrix.
How to connect remote identification: widget, SDK, API or your environment
Terms
- Try the demo
- Cloud or deployment inside your perimeter
- Support under the contract, via a ticket system
Glossary of remote identification
- Customer identification
- Establishing information about a customer and confirming it under Federal Law No. 115-FZ before accepting them for service.
- Customer identification
- Simplified identification
- Establishing the full name and the passport series and number, confirmed by one of the three methods in cl. 1.12 of Art. 7 of Federal Law No. 115-FZ; permitted only for the operations in cl. 1.11.
- Simplified identification
- Identification without personal presence
- The statutory term for remote identification: through ESIA and the EBS, in the simplified procedure or by delegation.
- Remote identification
- Electronic identification
- A general name for identification through electronic channels; in Russian law — one of the methods in Art. 7 of Federal Law No. 115-FZ or in Federal Law No. 572-FZ.
- Electronic identification, eID
- ESIA
- The Unified System of Identification and Authentication — the Gosuslugi infrastructure; a source of confirmed information about the customer.
- ESIA
- UBS
- The Unified Biometric System: stores face and voice vectors and returns a degree of match during identification and authentication.
- Unified Biometric System
- Authentication
- Confirmation that an already identified customer is applying; for online loans of microfinance organisations — through ESIA and the EBS.
- Authentication
- Delegation of identification
- Carrying out identification under a contract by another organisation expressly named in the law; responsibility stays with the delegating party.
- Reliance, outsourcing of CDD
- Customer profile
- A record of the information obtained during identification; stored for at least 5 years after the end of the relationship.
- Customer profile
- Verification
- A check that a person is who they claim to be: document, face, data. Not equivalent to identification under Federal Law No. 115-FZ.
- Verification
Read also
167 18
KYC, AML and Digital Identification
Unified Biometric System (EBS): What It Is, How to Enroll Your Biometrics, and Where It’s Used
114 29
KYC, AML and Digital Identification
115-FZ: What Businesses Are Required to Do and How to Meet the Law’s Requirements
373 13
KYC, AML and Digital Identification
Digital KYC and e-KYC: how real-time remote identity verification works
375 22
KYC, AML and Digital Identification
Fintech Compliance Under Federal Law 115-FZ: How to Build a KYC and AML Loop Without Overloading the Team
Frequently asked questions about remote identification
It is establishing and confirming information about a customer without a visit to the office by the methods expressly permitted by Federal Law No. 115-FZ: through ESIA and the EBS, in the simplified procedure or on the instruction of another organisation. Other online checks are verification under the company's own rules.
A passport photo does not by itself make identification lawful: the method matters. In the simplified procedure the passport information is confirmed through state systems and by a code sent to the phone; for full identification without personal presence, banks and organisations supervised by the Bank of Russia need ESIA and the EBS. A passport photo with recognition and anti-fraud is the basis of each of these routes.
In the scope of information and the range of operations. Simplified — the full name and passport, confirmed by one of three methods, and only for the operations in cl. 1.11 of Art. 7. Full — the whole set of information, including address and citizenship.
Banks and other organisations supervised by the Bank of Russia (except branches of foreign banks) under the conditions of cl. 5.8 of Art. 7 of Federal Law No. 115-FZ. For microfinance companies this route became the only remote one from 1 March 2026, for microcredit companies it will from 1 March 2027.
No: the obligation to identify rests with your organisation, and it can be delegated only to persons expressly named in the law. NeuroVision provides the tools — the document, database checks, liveness, EBS integration and the session log — with which you carry out identification yourself.
Yes, the EBS integration is connected in your environment: the document, database checks and the EBS query run in one scenario. The cost of EBS queries is set by its operator.
Microfinance organisations — no: for microfinance companies the ban applies from 1 March 2026, for microcredit companies from 1 March 2027. Banks issue consumer loans under simplified identification only up to 15,000 ₽ and with the money transferred under the payment system rules (cl. 1.12-1 of Art. 7).
Liveness and comparison of a selfie with the photo in the document are part of the "Document + liveness" package and protect against impersonation. How to use them in your scenario in light of Federal Law No. 572-FZ, agree with your lawyer. More — on the page about verification by passport and selfie.
If your activity is not listed in Art. 5 of Federal Law No. 115-FZ, you have no obligation to identify under this law — you check the customer under your own rules and contract. If it is, but you are not supervised by the Bank of Russia, delegating identification to a credit institution is usually available. In both cases NeuroVision covers the checking of the document and the data.
Certification authorities have their own procedure — Art. 18 of Federal Law No. 63-FZ "On Electronic Signature". An accredited certification authority may also carry out identification on a bank's instruction (cl. 1.5 of Art. 7 of Federal Law No. 115-FZ).
The platform issues the session result automatically, and the decision is made by your system under your rules. Where the law requires a person's involvement — on the page about digital onboarding.
In the NeuroVision cloud on servers in Russia or in your environment with on-premises installation. You keep the information from the customer profile for at least 5 years after the end of the relationship with the customer. More — KYC service in Russia.
We will choose a remote identification route for your company
Tell us who you are and what operation the customer performs — we will show which steps and checks to put in the scenario, and give you test access. Customer identification for your case — without a visit to the office.
Can't put your request into words? Book a call and our team will contact you at a convenient time
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