US banks and credit unions can now use qualifying mobile driver’s licences (mDLs) to verify new customers under clarified federal guidance, but integrating the credentials into existing onboarding systems remains a challenge.
In an analysis published by digital identity provider Hopae, the company argues that the regulatory clarification removes a key source of uncertainty for financial institutions, shifting attention towards the technology needed to support digital identity verification.
On 8 September 2026, the Financial Crimes Enforcement Network (FinCEN), alongside staff from the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA) and Office of the Comptroller of the Currency (OCC), issued guidance on using state-issued mDLs and other government-issued verifiable digital credentials.
Hopae notes that the announcement does not introduce a new law or require banks to accept digital identification. Instead, the guidance clarifies how existing customer identification requirements apply to qualifying digital credentials. FinCEN confirmed that the FAQs do not change Bank Secrecy Act obligations or establish new supervisory expectations.
Under the clarified interpretation, a state-issued mDL can qualify as government-issued identification for CIP purposes. Banks must continue to verify customer information, including name, address and date of birth, in line with their existing identification programmes.
The guidance also covers other government-issued verifiable digital credentials, subject to applicable requirements. These credentials must contain a photograph or equivalent safeguard and evidence of nationality or residence. Where a third party issues a credential, the financial institution remains responsible for verifying it to the required standard.
According to Hopae’s analysis, the distinction between a mobile licence and a photograph of a physical card is central to the change. A qualifying credential is digitally signed by its issuer, cryptographically bound to a device and protected by an activation factor such as a PIN or biometric authentication. These mechanisms allow the receiving institution to verify the credential’s authenticity rather than relying solely on the appearance of a document.
Many US mDL implementations follow ISO/IEC 18013-5, a standard supporting short-range verification between a mobile device and a reader. Hopae also highlights ISO/IEC 18013-7, published in 2024, which extends mobile driver’s licence verification to online interactions. This is relevant to banks that onboard customers remotely and need to authenticate digital credentials without requiring an in-person visit.
In a digital verification process, a bank can request a cryptographic response, validate the issuer’s signature against its public key and check whether the credential has been revoked. Hopae argues that supporting these processes requires a different technical approach from conventional document scanning, which is commonly built around images of physical identification cards.
The company points to a growing number of live mDL programmes across the US. According to the Secure Technology Alliance’s mDL Connection tracker, 20 states and territories operate live programmes built to the relevant standard. Hopae argues that the expansion of these schemes creates an integration challenge for banks whose existing identity verification systems were not designed to process cryptographically signed credentials.
Hopae Connect is the company’s proposed solution to this challenge. Hopae says its platform supports ISO/IEC 18013-5 mobile driver’s licences from around a dozen states and territories, including California, Arizona, Colorado and Georgia. It also supports credentials across Samsung Wallet, Google Wallet and Apple Wallet implementations, as well as Google’s ID Pass.
For financial institutions already using Hopae Connect’s API for CIP checks, the company says mDL verification can be added as another credential type within the existing integration, rather than requiring a separate project. This approach is intended to help banks incorporate digital identity options into their onboarding processes while maintaining established compliance controls.
Hopae’s analysis concludes that the regulatory clarification removes one obstacle to adoption, leaving technical readiness as the next challenge. Although customers can already hold verifiable identity credentials on their phones, banks still need infrastructure capable of accepting and validating them. For financial institutions assessing digital identity, the next step will be determining whether existing systems can support these credentials across both branch-based and remote onboarding.
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