Documentary vs Non-Documentary Verification (2024)

Even with flawless UX and fast internet, document verification can be a time-consuming process for users, resulting in them dropping off. But what if we told you that businesses can now onboard users in 45+ countries in milliseconds, with no need to upload or scan IDs?

Let’s compare documentary vs non-documentary verification, dive deeper into what document-free verification is, and explore its many benefits.

In this article, we use the term ‘document-free’ to describe verification methods that don’t involve uploading document scans. This includes verifying digital identity on  blockchain or through credit bureau checks. It’s important to note that ‘document-free’ is not synonymous with ‘Non-Doc,’ which exclusively refers to Sumsub’s Non-Doc Verification product.

Document verification: The traditional method

Document verification usually includes checking authenticity and accuracy of documents, such as passports, IDs, driving licenses, or financial records, to verify the identity of an individual. The process typically involves reviewing, cross-referencing, and comparing information on physical documents or scanned copies of them. This verification process is commonly used in various fields, including financial institutions, insurance companies, real estate services, etc.

More advanced document verification includes several security feature checks, such optical character recognition (OCR), pattern recognition, and MRZ decryption.

However, there are some challenges with traditional document verification methods:

• The need for manual checks. Verification of physical documents still may involve manual work, which can be time-consuming and inefficient. This can lead to delays in service provision and increased operational costs. 
• Furthermore, physical documents can be forged or altered, making it challenging to rely solely on the visual inspection of documents.
• The inconvenience of uploading documents. Document verification can be a big obstacle, especially when new users need to urgently access a service. Sometimes, documents simply aren’t at hand. 

For these reasons, the world is moving towards document-free verification.

Document-free verification

Document-free verification confirms identity quickly without relying on physical documents.

Methods of non-documentary identity verification include:

• Digital identity on blockchain, which many EU, MENA and CIS governments have provided as national digital IDs
• Credit bureau checks
• ID verification across databases through a certified third-party identity provider (Non-Doc Verification)
• Verification through Qualified Electronic Signatures

Non-Doc Verification

Non-Doc Verification is a document-free product from Sumsub, which provides a dependable and efficient alternative to ID-based user verification and onboarding. Its functionality involves extracting and verifying comprehensive customer data from government sources.

Non-Doc Verification includes:

• Identity verification
• Address verification

These can be applied separately or as a single product. Database validation is available as an additional security check. 

Non-Doc Verification is a completely standalone and secure procedure that works in two ways, depending on the country:

1. By extracting personal and biometric data from a government source based on an ID document number and liveness check
2. By extracting the required data attributes from banking records via account login and device authentication.

Depending on the jurisdiction, the entire KYC process may be substituted with Non-Doc, in addition to a Liveness check—a simple verification process completed in a matter of seconds.

Non-Doc offers the following benefits for business:

• A fully compliant IDV solution in 18+ countries
• Increased pass rates and fraud-free onboarding
• Scalability in new markets with 5+ billion new users
• Reduced errors and increased business performance, as user data is instantly updated in user profiles.

Document-free verification: The benefits

• Enhanced security. Document-free verification methods are difficult to forge or manipulate, making it harder for individuals to impersonate others. By cross-referencing ID data with government databases, organizations can reduce the risk of fraud, such as synthetic identity theft or the use of fake identity documents.
• Cost savings. Organizations can save on administrative costs associated with document handling and storage when using doc-free verification methods, especially when it comes to address verification.
• Accuracy. Government databases are typically highly accurate and up-to-date sources of information.
• Fast user onboarding. Document-free verification can be faster and more efficient for both businesses and users, as it eliminates the need for users to provide physical documents and reduces manual document review.
• Scaling across global markets. In some countries, like Brazil, document-free verification is most common. Businesses can also combine documentary and non-documentary verification methods for different jurisdictions.

Document-free verification: Primary vs. secondary 

Primary non-document verification confirms an individual’s identity without relying on traditional paper documents. This may involve the use of strong authentication measures, such as biometrics (fingerprint scans, facial recognition, etc.) or multi-factor authentication (combining something the user knows, like a password, with something the user has, like a smartphone for receiving a code). This process establishes the baseline identity of an individual before additional layers of verification may be applied, and is typically used by non-regulated entities. 

Secondary non-document verification adds additional layers to the primary verification process, including further checks against databases, behavioral analytics, and more. 

Suggested read: Customer Reverification: What It Is and Why It Matters. Complete Guide for 2024

Document-free verification and compliance

Document-free methods of identity verification can be Anti-Money Laundering (AML) compliant, but it depends on the region. Businesses must therefore ensure that their document-free verification methods comply with AML regulations in the jurisdictions where they operate and be aware of regulatory changes.

A combination of Non-Doc, along with the collection of additional documents or information, if applicable, the cross-checking of data, and the confirmation of identity through liveness can guarantee 100% AML compliance, even for high-risk cases.

The United States

Bank Secrecy Act (BSA), the main Anti-Money Laundering (AML) legislation in the US, describes which information needs to be collected about customers in “Customer Identification Program: minimum requirements” (CIP). 

The BSA also states that both documentary and non-documentary verification methods (as well as their combinations) are acceptable so long as
(i) the chosen procedures ‘’enable to form a reasonable belief that it knows the true identity of each customer”; and,
(ii) in case a non-documentary solution is elected, the firm applies additional procedures to address the risks where “the customer opens the account without appearing in person”.

Check this article to learn about detailed requirements of CIP.

US AML regulations could be compatible with non-documentary customer identification methods, however the AML-obligated entities performing it must be assured it knows the true identity of its customer. To ensure this, they can use additional KYC mechanisms, such as biometric checks. 

The UK

In the UK, document-free verification methods are approved by regulations and can be utilized by businesses.

Sumsub offers Non-Doc Verification in the country, which can be used for multiple use cases, including ID, address, phone number, and age verification. 

Sumsub’s Non-Doc Verification can be conducted in three stages:

• The user selects their bank and is instantly redirected to the bank’s login page 
• The user logs into their bank account and consents to share the required data
• Sumsub retrieves the verified data, confirms the customer’s identity automatically, and onboarding is complete.

Here are the benefits of Non-Doc Verification in the UK: 

• It’s done in approximately 4.5 seconds
• It relies on a banking app, so all that customers need is their bank account rather than a physical document.
• Data transfers are fully protected using the TLS 1.3 encryption protocol.
• It’s compliant with UK AML regulations, provided that additional security measures are incorporated. 

Other jurisdictions

Sumsub’s Non-Doc Identity Verification is 100% compliant in:

• 🇦🇷 Argentina
• 🇧🇷 Brazil
• 🇩🇰 Denmark
• 🇮🇳 India
• 🇮🇩 Indonesia
• 🇳🇬 Nigeria
• 🇳🇴 Norway
• 🇿🇦 South Africa
• 🇸🇪 Sweden
• 🇬🇧 UK
• 🇺🇸 USA
• 🇦🇺 Australia
• 🇨🇦 Canada
• 🇨🇴 Colombia
• 🇬🇭 Ghana
• 🇭🇰 Hong Kong
• 🇲🇹 Malta
• 🇵🇭 Philippines
• 🇦🇪 UAE
• 🇻🇳 Vietnam

FINTRAIL’s findings conclude that Sumsub’s Non-Doc Verification product meets compliance requirements across multiple jurisdictions.

“FINTRAIL has conducted a regulatory-led audit of Sumsub’s non-documentary identity verification product, and has reviewed local regulation and guidance in the markets where non-documentary identity verification is permissible to confirm the solutions deployed by Sumsub are compliant with local regulations and guidance.”

Sumsub Non-Doc Address Verification is compliant in:

• 🇦🇷 Argentina
• 🇧🇩 Bangladesh
• 🇧🇷 Brazil
• 🇮🇳 India
• 🇮🇩 Indonesia
• 🇰🇪 Kenya
• 🇳🇬 Nigeria
• 🇳🇱 Netherlands
• 🇿🇦 South Africa
• 🇬🇧 UK
• 🇺🇸 USA

Coming soon:

• 🇨🇮 Ivory Coast
• 🇳🇴 Norway
• 🇩🇰 Denmark
• 🇬🇭 Ghana

The above mentioned jurisdictions are those already checked by Sumsub. If your business operates in other jurisdictions, Sumsub’s experts can see whether Non-Doc is a compliant verification method there.
Non-Doc allows businesses to verify user data for over 5.5 billion people worldwide—all done quickly and securely without uploading multiple documents.

Use cases

Non-Doc Verification can be used by crypto, gambling, fintech, transportation, e-commerce, and other industries. It has multiple use cases, including user, address, and age verification. 

Non-Doc can be used as a standalone verification solution or in combination with other verification products. Some use cases include user pre-verification, where data is pre-screened before the full onboarding process, and user post-verification, which double-checks information submitted during the onboarding process.

A combination of Non-Doc with a document-based method could be a bulletproof option for high-risk cases or where regulations require checking the customer’s identity against multiple sources. 

Non-Doc may be used for continuous monitoring with reliable data instantly updated in user profiles.

FAQ

• What are some non-document methods of verification?

  Non-document verification methods may include public databases or other 3rd party electronic ID verification services.

• What are some examples of non-document verification?

  Sumsub’s Non-Doc Verification (checking ID numbers through certified ID providers, like banks in the UK) is the best example of a document-free verification method. 

• When can the non-doc method of customer information verification be used?

  The non-doc method of customer verification may be used in different industries, including fintech, crypto, e-commerce, iGaming, transportation, and insurance businesses. There are multiple use cases, including identity, age, and address verification.

Disclaimer: The information provided in this article is for general informational purposes only and is not intended to constitute legal advice.