Financial Institutions Can Now Use Mobile Driver’s Licenses to Meet CIP Requirements
FinCEN recently issued a ruling that explicitly allows banks and credit unions to accept state-issued mobile driver's licenses (mDLs) for customer identity verification under the CIP Rule. Docusign ID Verification will soon support mDLs, enabling one-tap, KYC-grade verification for financial institutions.
For financial consumers, the need to provide proof of identity when opening a new account online is often a frustrating experience. Manual identification uploads introduce friction, slowing completion and raising security concerns. In Entrust’s Digital-First Banking Report opens in a new tab, 37% of consumers said they had abandoned a new bank account application. Among those who abandoned, 47% cited a process that felt insecure or too cumbersome. This can leave applications incomplete and contribute to customer or member dissatisfaction with their financial institution.
Yet identity verification is a crucial step in the customer journey and is necessary to meet stringent regulations, including Know Your Customer/Anti-Money Laundering (KYC/AML) requirements.
Docusign makes it easier for consumers to verify their identity, integrating with over 80 different identity providers worldwide through a federated identity network. Docusign supports a consistent, low-friction user experience backed by a complete audit and evidence record.
Docusign Identify—part of the Docusign Intelligent Agreement Management (IAM) platform—enables users to confirm their identity using a mobile device. Once verified, users can store their credentials in a reusable Identity Wallet for subsequent interactions without re-verification, while maintaining the same level of trust.
Despite these clear benefits, banks and credit unions have had difficulty using wallet-stored credentials for identity verification due to a lack of regulatory clarity regarding verifiable digital credentials (VDCs).
FinCEN’s ruling: mDLs now qualify as documentary identity verification
On September 9, 2026, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) explicitly stated that government-issued VDCs can be used opens in a new tab to verify identity in-person, online, or through other digital channels, and that such credentials meet the requirements for the Customer Identification Program (CIP) Rule under 31 C.F.R. § 1020.220. It also clarified that the VDC category includes unexpired state-issued mobile driver's licenses (mDLs). Such government-issued VDCs must “evidence nationality or residence and bear a photograph or similar safeguard.”
FinCEN’s clarification was issued jointly with the Federal Reserve, FDIC, NCUA, and OCC in the form of answers to two new frequently asked questions (FAQs) opens in a new tab and an update to one existing FAQ. Importantly, FinCEN states that “the CIP Rule neither requires nor prohibits reliance on such government-issued VDCs as a means of verifying a customer’s identity.”
What does FinCEN’s mDL ruling mean for financial institutions?
With this clarification, it’s now possible for financial institutions to accept state-issued mDLs to verify account holders' identities under the CIP rule. The availability of mobile driver’s license options varies by U.S. state and territory. Currently, 21 U.S. states and Puerto Rico opens in a new tab support mDLs and state IDs.
This rule clarification explicitly supports the use of all digital credentials, including those issued by government entities and by approved private third parties such as CLEAR or ID.me. However, for the non-government third-party issuers, the financial institution remains responsible for ensuring that the third party uses the same level of authentication as the bank or credit union would.
This important distinction elevates government-issued digital documents (including mDLs) to a higher level of regulatory acceptance, because a qualifying government-issued credential can be treated as a documentary method of verification under the rule.
Docusign is launching mDL support for identity verification
Coming soon, Docusign will begin accepting mDLs. The experience will be secure and seamless for users, allowing them to progress quickly from verification to a completed signing session.
Financial institutions will have the same level of auditability and evidence for their transactions available within the trust record for the Docusign eSignature transaction.
With the latest FinCEN rule clarification, banks, credit unions, and other financial institutions have received the regulatory approval to use digital IDs like mDLs within their customer and member engagement processes on the Docusign platform for identity verification. Verified data extracted from the driver’s license can be used to automate downstream processes, reducing the incidence of “not in good order” (NIGO) documents, and supporting streamlined straight-through processing (STP) opens in a new tab. The existing "proof of verification" evidence record captures the verification status and ID data into the existing systems of record and in the attached certificate of completion (CoC), regardless of whether an mDL or physical ID card is accepted.
With this enhancement, Identify offers an alternative to manual document uploads with a biometric-backed, selective-disclosure experience, while providing banks and credit unions with audit-ready ID evidence to support compliance requirements.
For consumers, verifying their identity will be as easy as one click with a government-issued mDL.
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