AFIA responded to the Identity Verification Services Amendment (Participation Agreements) Rules 2025 Consultation

Written By Sarah Perry

On 2 June 2025, AFIA responded to the Identity Verification Services Amendment (Participation Agreements) Rules 2025 Consultation.

The Document Verification Service (DVS) is essential for KYC, onboarding, and meeting compliance obligations across the financial sector. Timely execution of participation agreements is necessary to avoid disruption to services.

While the signature deadline is being extended, compliance obligations would still commence based on the original timeline. Early signers may face the burden of meeting privacy, security, and attestation requirements from mid-June 2025 – with just four months of lead time. Participation Agreements (PA) may require changes to data handling, legal frameworks, internal controls, and audit processes.

AFIA recommends that:

  • The six-month extension should apply not only to the PA signing deadline, but also to the start of compliance and attestation obligations.

  • All DVS users – including early signers – should be given a common compliance start date (e.g. 1 January 2026) to support implementation equity and reduce complexity.

 View the PDF here.

Sarah Perry
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AFIA submission to ASIC consultation paper 383 on ‘Reportable situations and IDR data publication’