On 27 August 2026, HSLU and Eurospider Information Technology AG presented the results of their joint study on the digital onboarding of corporate clients at an invite-only breakfast roundtable. The group of compliance, risk and digitalisation leads from banks, joined by experts from law and academia, engaged in a substantive, level-headed exchange on the gap between regulatory ambition and practice.
Four Clusters, One Focus: Compliance
The aim of the study was to use objective criteria to bring traceability to a largely unexplored field for the first time. It structures digital onboarding along four requirements that financial intermediaries must meet simultaneously: customer experience, business orientation, technology and compliance. The event focused on customer experience and business orientation.
The “Funnel of Reality”: From 282 to 2
The centrepiece was the “Funnel of Reality”, based on the HSLU test dataset (n = 282):
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Stage
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Number
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Financial intermediaries (banks, securities dealers, Art. 1b fintech licence holders)
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282
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…of which offer digital onboarding for corporate clients
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26
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…of which were tested by HSLU
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13
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…of which have confirmed functioning digital onboarding for corporate clients
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2
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Only 2 out of 282 financial intermediaries have confirmed functioning digital onboarding for corporate clients – a figure the panel described as “surprisingly low”, and one that reveals the gap between ambition and the reality of implementation.
Client Perspective: Friction in the Details
Recurring friction points: clients expect pre-filled data from the commercial register and structured response fields instead of free text; they often question whether the information requested is really necessary; terms of use sometimes seem redundant to clients, while banks consider them necessary; and above all, time is decisive – uncertainty about the duration of the process and follow-up appointments leads to drop-offs. From a business perspective, digitalisation delivers noticeable efficiency gains for relationship managers, but risk assessment should remain “human in the loop” rather than fully automated.
Control Structures and the Transparency Register: The Limits of Self-Declaration
Peter Schäuble (Co-CEO Eurospider) gave an insightful presentation on complex control structures. Using multi-tiered and circular shareholding chains, he showed how challenging it becomes to identify beneficial owners once shareholders’ agreements come into play – often, not even the company itself reliably knows who holds the de facto voting majority through such an agreement.
It remained unclear how such structures can be captured accurately enough to be entered correctly in the transparency register. At its core, the Anti-Money Laundering Act (AMLA) only requires a self-declaration for this: if a controlling relationship is not reported, the institution effectively has no knowledge of it. Under the TJPG, the supervisory authority may order enforcement measures if duties to cooperate are breached, up to and including the suspension of membership and property rights (Art. 38, 49 TJPG).
A contentious point was whether the ongoing AMLA revision will replace this self-declaration with “control by other means” – with an obligation for institutions to verify information in future rather than merely accept it. The panel named the revised FINMA requirements on video and online identification as a further open area of tension.
AI Agents in Onboarding: Authority to Act and Attribution
The panel also discussed the increasing use of AI agents acting on behalf of corporate clients. Open questions: How does a bank verify and document an agent’s authority to act – is an explicit client power of attorney required, how does it remain valid over time, and how can the agent’s actions be attributed to the authorising person? The panel saw considerable, but as yet unstructured, need for clarification.
Voices from the Panel
Eva Selamlar-Leuthold (Co-CEO Eurospider), Dr Peter Schäuble (Co-CEO Eurospider), Dr Thomas Fischer (HSLU IFZ) and Prof. Dr Cornelia Stengel (Kellerhals Carrard / HSLU) discussed recurring themes: innovation potential lies in the details, not in the big concept; every onboarding case played out differently; and the question of which actions an AI system may take on a client’s behalf with legally binding effect was explicitly left open.
Conclusion
Of the 282 financial intermediaries examined, 26 offer digital onboarding for corporate clients and 13 were tested - it actually works for only two of them. The biggest open questions lie beneath the surface: complex control structures, the binding nature of shareholders’ agreements, the future of self-declaration under the AMLA revision, and the legal classification of AI agents. HSLU and Eurospider intend to continue the study and expand the test dataset.
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