Are VideoIdent’s Days Numbered? What’s Changing in German Investor Identification

For fund managers and administrators onboarding German investors, the most friction-heavy step in the subscription process, live video identification with an agent, could soon be replaced by a fully automated one, ahead of the EU AML Regulation applying in July 2027.

In July, we asked whether this was the end of VideoIdent in Germany. At the time, the DIdG was a Cabinet draft and the EU’s rules on remote identification were still out for consultation. Both have moved forward since, and the picture is getting clearer.

TL;DR

• On 15 October 2026, the Bundestag adopted Germany’s Digital Identity Act (DIdG). The Bundesrat’s consent is the last step before it enters into force.
• Once in force, a qualified electronic signature (QES) is enough to identify investors under the German Money Laundering Act (GwG), without a reference bank transfer.
• The obligation to validate the QES stays, and so does the fund manager’s responsibility for the identification.
• The EUDI Wallet becomes a permitted identification method. Germany’s wallet, d-you, is scheduled to launch on 2 January 2027.
• AMLA’s final standards on customer due diligence keep VideoIdent available, but only as a justified alternative to electronic identification.

What Happened Since July

The Bundestag adopted the DIdG on 15 October 2026. Its committee made several changes to the wallet provisions, but left the amendments to the GwG exactly as the government had drafted them.

The law requires the consent of the Bundesrat, the chamber of the federal states. Once it consents and the law is promulgated, it enters into force the following day. Until then, the current rules continue to apply.

What Changes in the GwG

The amendments to the GwG are short, but they address exactly the step that makes German investor identification cumbersome today.

The most important one for private funds is the deletion of the reference transfer requirement. Today, identifying an investor via QES only works if a transaction is also made from a bank account in the investor’s name. Once the DIdG is in force, the QES alone is sufficient. The government’s reasoning: the EU AML Regulation (AMLR) already accepts a QES without a reference transfer from July 2027, and removing the requirement early avoids putting German firms at a competitive disadvantage.

What does not change is who carries the responsibility. A QES is a trust service regulated under the EU’s eIDAS Regulation: the provider verifies the signer’s identity in order to issue it, but it does not perform customer due diligence for the fund. That happens when the fund manager, or the administrator acting on its behalf, validates the signature and decides to rely on it as identification. The GwG’s requirement to validate the QES in line with eIDAS stays in place; only the reference transfer goes. In practice, that validation should be automated and documented, so the KYC file shows not just a signed document, but a verified one.

VideoIdent itself is not affected. The DIdG does not change BaFin’s circular, so VideoIdent remains a permitted method in Germany. What changes is that it is no longer the only practical way to identify an investor remotely without extra steps.

The DIdG also adds the EUDI Wallet to the list of permitted identification methods. Record-keeping changes accordingly: where an investor identifies with the wallet, firms no longer keep a copy of the ID document, but the electronic data generated when the wallet’s identification data is authenticated and validated.

d-you: The Next Milestone to Watch

Germany’s state wallet, d-you, is scheduled to launch on 2 January 2027. The Federal Ministry for Digital Affairs and State Modernisation (BMDS) announced it on 9 September 2026.

For investors, it adds a further way to identify themselves from their phone, without a video call and without uploading an ID document.

For fund managers, accepting the wallet does not happen automatically. Anyone requesting data from a wallet must be registered as a relying party and declare in advance which data it will request, limited to what the intended use actually requires. In practice, many firms will work through an identity provider, which under eIDAS is itself treated as a relying party when it acts on a firm’s behalf. Either way, responsibility for the identification under the GwG stays with the fund manager, and the validation records the GwG now requires need to end up in the investor file in a form an auditor can follow.

Expectations should stay realistic. Awareness is still low: in a survey of 2,000 consumers in France and Germany published by IDnow in July 2026, 51% had never heard of the EUDI Wallet and only 20% had a clear understanding of what it does. Adoption will take time to build after launch, and investors outside the EU will not have a wallet at all. For most German fund onboardings in early 2027, QES without a reference transfer is likely to be the practical route. The wallet is the one to start preparing for.

What AMLA’s Final Standards Mean for VideoIdent

On 1 October 2026, AMLA submitted its final draft regulatory technical standards on customer due diligence under Article 28(1) AMLR to the European Commission. Compared to the consultation draft we covered in July, the wording on remote identification was revised.

The final draft recognises two standard routes:

• an identity document, either presented in person or as a verified copy, and
• electronic identification means or qualified trust services, which include QES and the EUDI Wallet.

Remote document-based solutions, the category VideoIdent falls under, become an alternative: they can be used where an investor cannot reasonably be expected to present their ID in person and does not have access to electronic identification. Firms using them must be able to justify to their supervisor why the standard routes were not possible.

VideoIdent does not disappear. But it stops being a default and becomes a case-by-case exception that needs documenting. The standards still need to be adopted by the Commission and published in the Official Journal, and they apply six months after entering into force.

Read together with the DIdG, the direction is consistent: Germany is making QES the easier route, and the EU is making it the expected one.

How Vestlane Supports Investor Identification in Germany

Vestlane already supports investor identification via QES. The identity check behind it can run fully automated or, where needed, via VideoIdent. Until the DIdG enters into force, the reference transfer still applies to QES-based identification under the GwG. Once it does, that step falls away. We are following the d-you launch closely as the wallet becomes part of the identification landscape.

If you are reviewing how your fund identifies German investors ahead of 2027, whether that means moving away from VideoIdent, preparing for the reference transfer to drop, or understanding what accepting the wallet would involve, our team is happy to talk it through.