Bitkom welcomes EBA’s draft guidance for remote customer onboarding to fulfill Know-Your-Customer (KYC) requirements at this particular point in time. We want to further point out that we appreciate the close alignment with eIDAS, which is regarded to create greater harmonization. Amendments to remote KYC onboarding legislation continue to evolve, but there remains fragmentation between national law, which poses risks to security and effects service across Member States. Particularly, Germany’s NCA (BaFin) is known for a restrictive use of KYC-compliant remote customer onboarding which poses a severe disadvantage for German financial institutions. The need for maintaining robust security and data privacy provisions is paramount for the digital identity verification ecosystem.