Simplified Customer Identification Under 115-FZ: Who May Use It and How to Carry It Out

Simplified identification of a customer who is an individual is a separate procedure of Federal Law No. 115-FZ “On Combating the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism” with a short set of information: only the full name and the series and number of the identity document. It is carried out for a closed list of transactions — transfers without an account, certain types of insurance and lending, lottery winnings, and a number of other cases under Article 7(1.11), each with its own monetary threshold; the accuracy of the information is confirmed by one of three methods (Article 3, Article 7(1.12)).

What Simplified Identification Is and How It Differs From Full Identification

Full identification of an individual establishes considerably more: surname, first name, patronymic, citizenship, date of birth, the details of the identity document, migration document data (if applicable), the address of the place of residence or stay; the TIN — for a digital record-keeping agreement, a brokerage service or trust management agreement providing for transactions with digital currencies and/or digital rights, and for the purchase and sale of digital currencies, and in other cases — if available (Article 7(1)(1)). Simplified identification — only the full name and the document series and number. The difference is not a formality: the smaller set of information is precisely the reason the law allows it only for a predetermined list of an individual’s transactions — not as the general procedure for accepting a customer for service. The full range of obligations that 115-FZ imposes on businesses in general, beyond customer identification, is covered in the article “115-FZ: What Businesses Are Required to Do and How to Meet the Law’s Requirements”.

The 115-FZ concept also does not coincide with the international FATF term “simplified due diligence” — that is a concept from another system of categories, from the FATF recommendations, not a Russian legal provision, and one should not be substituted for the other.

An important restriction on the circle of customers: simplified identification applies only to a customer who is an individual. The provision does not apply to legal entities at all: for them, the law knows only identification with the full set of information (representative, beneficiary, beneficial owner — separately).

Which Transactions Simplified Identification Is Allowed For

The closed list of transactions and agreements for which simplified identification may be carried out is set out in Article 7(1.11) of 115-FZ. Most items have their own monetary limit:

The same list in Article 7(1.11) names eleven more items without a separate monetary limit in the provision itself: providing a customer who is an individual with an electronic means of payment (an independent ground, separate from a transfer without an account); agreements with non-state pension funds; a brokerage service agreement and a securities trust management agreement — except where such an agreement provides for transactions with digital currencies and/or digital rights: for those, simplified identification does not apply at all (Article 7(1.12-5)); an investment advisory agreement; opening a personal account in a register of securities holders; maintaining such an account — only in the case established by Article 7(1.4-6); a depository agreement; registrar entries on transactions made using a financial platform; an agreement with a financial platform operator for transactions for which the law provides for simplified identification; acquisition of units of unit investment funds. In total, the closed list of Article 7(1.11) contains twenty items.

These thresholds are not the same as the cases in which no identification is carried out at all: payments by individuals up to ₽15,000 (Article 7(1.1)); insurance premiums — for life and pension insurance up to ₽15,000, for other insurance agreements up to ₽40,000 (Article 7(1.1-1)); taxes and housing and utility payments up to ₽60,000 (Article 7(1.1), (1.4)); cash foreign currency up to ₽40,000 (Article 7(1.2), paragraph 1); exchange or replacement of banknotes and coins up to ₽40,000 (Article 7(1.2), paragraph 2); transfers to legal entities and individual entrepreneurs and postal transfers in their favor up to ₽15,000–60,000 (Article 7(1.4), (1.4-7)); lottery winnings of less than ₽15,000 (Article 7(1.4-4)). This is a different regime: under it, the customer is identified neither fully nor in simplified form — these thresholds are often confused with the conditions for simplified identification, although these are different cases.

The ₽100,000 limit for transfers without an account and for interactive bets is part of a broader ladder of thresholds that Federal Law No. 161-FZ “On the National Payment System” sets for electronic money: without customer identification, the balance is limited to ₽15,000 and turnover to ₽40,000 per month (Article 10(4) and (5)); after simplified identification, the balance rises to ₽100,000 and turnover to ₽200,000 per month (Article 10(5.1)); after full identification, a balance of up to ₽600,000 is allowed (Article 10(2)). Separately, the law prohibits using a non-personalized electronic means of payment to transfer money to another individual or to receive a transfer from one for a customer who has not completed simplified identification (Article 10(5.2) of 161-FZ). 161-FZ sets its own procedure of restrictions for the account itself separately — it is covered in the article “Blocking Under 161-FZ for Companies and Individual Entrepreneurs: What the Bank Suspends, How the Bank of Russia Database Works, and How to Get Out of It”.

Three Conditions That Must Be Met Simultaneously

Simplified identification of a customer who is an individual is carried out only if three conditions are met simultaneously (Article 7(1.11), paragraphs 2–5):

• the transaction is not subject to mandatory control, and the customer who is an individual is neither a person included in the list of organizations and individuals about whom there is information on their involvement in extremist activity or terrorism, nor a person in respect of whom the interdepartmental coordinating body for combating the financing of terrorism and extremist activity has decided to freeze (block) funds or property, nor a person included in the lists of organizations and individuals linked to terrorism or the proliferation of weapons of mass destruction compiled under decisions of the UN Security Council;
• the organization’s employees have no suspicion that the customer’s purpose is the legalization of criminal proceeds or the financing of terrorism;
• the transaction is not convoluted or unusual in nature, does not indicate the absence of an obvious economic purpose or a lawful aim, and gives no grounds to believe that its purpose is to evade mandatory control procedures.

How the assessment of customer and transaction risk that underlies such suspicions and decisions on assignment to risk groups works is covered in the article “The Bank of Russia’s Know Your Customer Platform: What a Risk Zone Means for a Company”.

When the Organization Is Required to Switch to Full Identification

If doubts arise about the accuracy of the information provided by the customer within simplified identification, or suspicions of the legalization of proceeds or the financing of terrorism, the organization is required to identify the customer in the full procedure of Article 7(1) (the last paragraph of Article 7(1.11)). This is not a discretionary right — it is an obligation that is triggered by the first of the two grounds. What exactly a bank is entitled to request additionally when switching to full identification, including about the source of the customer’s funds, is covered in the article “Source of Funds: What a Bank Is Entitled to Request and How to Confirm It”.

Three Methods of Carrying Out Simplified Identification

Simplified identification of a customer who is an individual is carried out by one of three methods (Article 7(1.12), mirrored in Article 3).

Method 1 — Presenting Documents in Person

The customer presents original documents and/or duly certified copies of documents in person.

Method 2 — Customer Information Confirmed via State Systems, Plus a Code to the Phone

The customer sends the organization (including electronically) information about themselves: full name, the series and number of the identity document, the individual insurance account number (SNILS) and/or the TIN, and/or the compulsory medical insurance (CMI) policy number, and/or the driver’s license number, as well as a mobile phone number.

A separate provision — Article 7(1.13) — describes when the customer is deemed to have completed this procedure: if the organization has received, including via the Interagency Electronic Interaction System (SMEV), from the information systems of public authorities, the Social Fund of Russia, the Compulsory Medical Insurance Fund, or a state information system designated by the Government, confirmation that the declared information matches, and the customer has confirmed receipt, at the specified number, of a code that ensures completion of the procedure. This mechanism is expressly named for a transfer without an account (including electronic money), accepting an interactive bet or paying out winnings, providing an electronic means of payment, consumer credit (a loan) subject to Article 7(1.12-1), agreements with non-state pension funds, securities trust management, a depository agreement, brokerage services, investment advice, opening a personal account in a register of securities holders, maintaining such an account — in the case established by Article 7(1.4-6), an agreement with an investment platform operator for investment facilitation services, insurance subject to Article 7(1.12-2), lottery winnings subject to Article 7(1.12-3), acquisition of units of unit investment funds, registrar entries on transactions made via a financial platform, and an agreement with a financial platform operator. Three transactions — exchange of banknotes, postal transfer, and purchase or sale of cash foreign currency — are not on this list: the provision under which the customer is deemed to have completed simplified identification after a SMEV check and a code to the phone does not apply to these three transactions.

In Letter No. 12-4-2/1299 of 27 February 2023 (issued with regard to MFOs before 41-FZ), the Bank of Russia stated that a customer may be deemed to have completed simplified identification if the information has been confirmed via the Federal Tax Service (FNS) data type “Information on the Correspondence of an Individual’s Passport Data and TIN” and the customer has confirmed the code to the phone, but separately warned that using only the FNS data type in SMEV without the data types of the Ministry of Internal Affairs (MVD) may increase the risks of improper customer identification.

Method 3 — Authorization in the ESIA

The customer completes authorization in the Unified Identification and Authentication System (ESIA, Gosuslugi (State Services)) using an enhanced qualified electronic signature (UKEP) or a simple electronic signature, stating the full name and SNILS. The condition applies only to the simple electronic signature: its key must have been issued provided that the individual’s identity was established at an in-person appointment. The provision sets no such condition for the UKEP.

The Unified Biometric System (EBS) is not on this list under any of the three methods — neither in Article 3 nor in Article 7(1.12). Methods 1–3 exhaust the list; simplified identification and the EBS are mechanisms of the law independent of each other — more in the section on remote identification below.

If simplified identification is carried out by an electronic money operator, it is required to give the customer the option of choosing any of these three methods (161-FZ, Article 10(5.3)).

Who Carries Out Simplified Identification and to Whom It Can Be Delegated

An organization required to carry out identification under 115-FZ is entitled to delegate the performance of identification or simplified identification to a certain circle of persons — for each category of organizations the provision names its own list and states separately whether simplified identification is named in this delegation or not:

Excluded from the circle of Article 7(1.5-1) are professional securities market participants engaged exclusively in investment advisory activities and health insurance organizations engaged exclusively in compulsory medical insurance; foreign insurance organizations are separately included in the same circle.

Responsibility for compliance with the requirements for identification or simplified identification rests with the organization that delegated their performance (Article 7(1.6)). Of the performers, only those named in Article 7(1.7) are liable under the law — credit institutions, lottery operators, federal postal service organizations, mobile radiotelephone operators, an accredited certification authority, financial platform operators, DFA information system operators, digital depositories, professional securities market participants engaged in brokerage or securities management, fund management companies; payment aggregators are liable for identification only under an agreement with a credit institution. Performers to whom tasks are delegated under Article 7(1.5)–(1.5-2) and (1.5-6)–(1.5-10) are additionally liable under the terms of the agreement, including a penalty (Article 7(1.8)). The performer is required to transmit the information obtained to the delegating organization immediately, but no later than three business days (Article 7(1.9)). Organizations supervised by the Bank of Russia are required to inform it of to whom they have delegated identification or simplified identification (Article 7(1.10)).

Until 3 March 2026, a credit institution could also delegate the identification and simplified identification of customers who are individuals to a bank payment agent; 44-FZ excluded it from Article 7(1.5), paragraph 1 — specifically for customers who are individuals. Delegation in respect of customers who are legal entities and individual entrepreneurs to a payment aggregator (paragraph 2 of Article 7(1.5)) is not affected. The period for bringing agreements into line is 180 days (Article 3(2) of 44-FZ); the calendar date of 3 March 2026 is named by the Bank of Russia publication of 16 March 2026. Even before this reform, the law allowed a bank payment agent’s subagent only transactions that do not require identification or simplified identification of the customer (161-FZ, Article 14(4)).

MFOs, Payment Agents, Communications Operators, Bookmakers: What the Law Allows

Microfinance Organizations

The use of simplified identification is not permitted for the purpose of a microfinance organization concluding a consumer credit (loan) agreement (Article 7(1.12-1), paragraph 2, of 115-FZ) — the provision was introduced by 41-FZ and does not apply from a single date for all MFOs. Microfinance organizations are divided into microfinance companies (MFKs) and microcredit companies (MKKs) — under Article 2(1)(2.1) and (2.2) of Federal Law No. 151-FZ (the law on microfinance activity). The prohibition and the related obligation of remote identification via the ESIA and the EBS (Article 7(5.8-2)) apply to MFKs from 1 March 2026, and to MKKs separately, from 1 March 2027 (Article 16(5) and (6) of 41-FZ). Until that date, the prohibition does not yet extend to MKKs.

Writing “simplified identification is prohibited for MFOs” without these two dates is incorrect: until 1 March 2027, the prohibition applies only to microfinance companies — it does not yet extend to microcredit companies. The status of a specific organization and the date applicable to it need to be checked separately from the general wording of the prohibition.

When accepting a customer who is an individual for service remotely, microfinance organizations are required to identify the customer and the customer’s representative via the ESIA and the EBS (Article 7(5.8-2), paragraph 1); when concluding each consumer credit (loan) agreement remotely, they are required to ensure the authentication of the customer by the same method — provided that identification at the preceding acceptance for service was already carried out by this method (Article 7(5.8-2), paragraph 2). Delegating simplified identification to a credit institution is still possible (Article 7(1.5-2)) — except in precisely this prohibited case with a consumer loan.

Payment Agents and Payment Acceptance Operators

A payment agent (Federal Law No. 103-FZ) is a separate category from another law: it is not the same as the bank payment agent discussed in the previous section. A “payment acceptance operator” is named in Article 5 of 115-FZ among the organizations on which the law imposes obligations, but accepting payments as a transaction is not on the closed list of Article 7(1.11): the provision does not give this category the right to simplified identification. For their transactions, separate thresholds apply below which no identification is carried out at all — transfers by individuals up to ₽15,000 (Article 7(1.1)).

Communications Operators

A mobile radiotelephone operator is also a category named separately in Article 5, and it can be delegated the performance of simplified identification: by a credit institution (Article 7(1.5)) and by a lottery operator (Article 7(1.5-7)). But Article 7(1.11) contains no transaction of its own for which a communications operator itself, for its own purposes, would be entitled to carry out simplified identification of a customer. When a communications operator itself acts as the delegating party and passes the task to a credit institution (Article 7(1.5-10)), the provision names only identification — simplified identification is not in this provision. Whether a specific company in the communications industry acts as the delegating party or as the performer in this scheme is worth checking before planning its own customer verification procedure.

Bookmakers and Totalizators

When accepting an interactive bet and paying out winnings on it, simplified identification may be carried out — within the electronic money balance limit under Article 10(5.1) of 161-FZ, that is, up to ₽100,000 (Article 7(1.11), (1.13)). A gambling organizer in a bookmaker’s office or totalizator is entitled to delegate the performance of identification or simplified identification to a credit institution performing the functions of the single center for recording transfers of bets (Article 7(1.5-6)).

Companies that need to solve both tasks at once — meet the 115-FZ requirements for customer identification and provide online acceptance for service without a personal visit via the ESIA and the Unified Biometric System — usually start with a ready-made integration with the EBS rather than developing one from scratch; an overview of what such an integration requires is in the section “Integration With the EBS”. For the microfinance industry, compliance requirements and options for meeting them are collected separately on the page “KYC and AML for MFOs”.

Simplified, Full, and “Remote” Identification

115-FZ does not introduce the term “remote identification.” The law names two related mechanisms: identification without personal presence (Article 7(5.8)) and remote acceptance by MFOs (Article 7(5.8-2)); both are full identification without a visit by the customer and have nothing to do with simplified identification.

Credit institutions and other organizations supervised by the Bank of Russia (except branches of foreign banks) are entitled, when accepting for service, to identify a customer who is an individual or a representative of a customer that is a legal entity without personal presence, using the ESIA and the EBS, subject to a list of conditions: the customer, the representative, and the beneficial owner are not on sanctions and terrorist lists; the organization has no suspicion of the legalization of proceeds or the financing of terrorism; there is no record of unreliable information about the legal entity in the Unified State Register of Legal Entities (EGRUL); and a number of others (Article 7(5.8)).

If a bank with a universal license that meets the criteria of Article 7(5.7) provides customers who are individuals with the option of opening accounts (deposits) and/or obtaining ruble loans through its website and/or mobile app at all, it is required to provide acceptance for service for these same services without personal presence, in the procedure of Article 7(5.8): a systemically important credit institution — through both the website and the mobile app at the same time, other banks — through the website and/or the app (Article 7(5.8-1)).

Placing biometrics in the EBS is a separate step, not part of simplified identification and not a prerequisite for it. With the customer’s consent and free of charge, a bank with a universal license that meets the same criteria is required (and a bank with a basic license is entitled), after carrying out identification in the customer’s personal presence, to place or update the customer’s information and biometric personal data in the ESIA and in the Unified Biometric System (Article 7(5.6)). The customer’s refusal to place biometrics in the EBS may not be a ground for refusing service (Article 7(5.6), paragraph 3).

The prohibition on opening an account (deposit) without personal presence does not apply if the customer who is an individual was identified by the same credit institution in personal presence (or in the case of paragraph eight of Article 7(5)), is serviced by it, and the information about the customer is updated; if suspicions arise, the exception does not apply.

Common Mistakes

• Confusing the “no identification” thresholds with simplified identification. Transfers by individuals up to ₽15,000, insurance premiums up to ₽15,000–40,000 (Article 7(1.1-1)), taxes and housing and utility payments up to ₽60,000, cash foreign currency and exchange of banknotes up to ₽40,000, lottery winnings of less than ₽15,000 — these are cases where no identification is carried out at all (Article 7(1.1), (1.1-1), (1.2), (1.4), (1.4-4), (1.4-7)). This is a different regime, not a variety of simplified identification.
• Treating the EBS as a method of simplified identification. There are three methods, and all three are listed in Article 3 and Article 7(1.12); the EBS is not among them — it is an element of another mechanism, identification without personal presence (Article 7(5.8)) and remote acceptance by MFOs (Article 7(5.8-2)).
• Issuing a consumer loan by a microfinance company on the basis of simplified identification after 1 March 2026. For MFKs, the prohibition of Article 7(1.12-1), paragraph 2, applies from that date; for MKKs — only from 1 March 2027.
• Delegating the identification or simplified identification of customers who are individuals to a bank payment agent after 3 March 2026. From that date, it is excluded from the circle of persons to whom a credit institution is entitled to delegate this (Article 7(1.5), paragraph 1, as amended by 44-FZ); delegation in respect of customers who are legal entities and individual entrepreneurs to a payment aggregator is retained (paragraph 2 of Article 7(1.5)).
• Checking customer information only against the FNS data type, without the MVD data types. Such a check is not prohibited in itself, but in its letter of 27 February 2023 the Bank of Russia indicated that this may increase the risks of improper customer identification.

FAQ

For Which Customers Is Simplified Identification Permitted?

Only for customers who are individuals, and only for transactions from the closed list of Article 7(1.11) of 115-FZ — transfers without opening an account, certain types of insurance and lending, lottery winnings, and a number of other cases, each with its own monetary limit. Simplified identification does not extend to legal entities.

What Information Is Established During Simplified Identification?

Surname, first name, patronymic, and the series and number of the identity document — nothing more. The accuracy of this information is confirmed by one of three methods: presenting documents in person, sending information with confirmation via state information systems and a code to the phone, or authorization in the ESIA.

Can Simplified Identification Be Completed via Gosuslugi?

Yes — authorization in the ESIA (Gosuslugi) using an enhanced qualified or simple electronic signature is one of the three methods (Article 7(1.12)(3)). For a simple electronic signature, the provision sets a condition: the key must have been issued at an in-person appointment; for an enhanced qualified signature, there is no such condition.

Can an MFO Issue a Loan on the Basis of Simplified Identification?

For a microfinance company — no, since 1 March 2026 this is expressly prohibited (Article 7(1.12-1), paragraph 2, of 115-FZ). For a microcredit company, the prohibition takes effect later — from 1 March 2027; until that date, it does not yet apply to it.

Is the Unified Biometric System Used in Simplified Identification?

No. The three methods of simplified identification named in Article 3 and Article 7(1.12) do not include the EBS. The EBS takes part in another mechanism — identification without personal presence (Article 7(5.8)) and remote acceptance by MFOs (Article 7(5.8-2)).

How Does Simplified Identification Differ From “Remote” Identification?

115-FZ does not introduce the term “remote identification.” The law names two related mechanisms: identification without personal presence (Article 7(5.8)) and remote acceptance by MFOs (Article 7(5.8-2)) — both are full identification via the ESIA and the EBS, just without a visit by the customer. Simplified identification is a separate regime with a smaller set of information, a closed list of transactions, and no EBS; it can also be completed remotely (method 2 and method 3), but under different rules.