DEVELOPMENT OF THE BANKID SYSTEM IN UKRAINE: FEATURES OF OPERATION AND REGULATORY FRAMEWORK

Анотація

Introduction. The digital transformation of the financial sector and the development of e-governance in Ukraine have highlighted the need for reliable tools for remote identification of individuals that are compatible with the EU legal framework in the field of electronic identification and personal data protection. In this context, the BankID system of the National Bank of Ukraine has gradually acquired the status of a de facto national standard for remote identification. Methods. The methodological basis of the study consists of a systematic approach, methods of analysis and synthesis, historical and comparative legal methods, which are used to reveal the genesis, architecture, and institutional model of the NBU's BankID and compare it with European electronic identification schemes. Formal-logical and formal-legal methods were used to structure the array of regulatory and legal acts and formulate generalizations regarding the legal regime of the System, while statistical methods were used to analyze the dynamics of participant connection and service use in 2016-2024. Results. The two-block structure of the NBU's BankID regulatory framework (general acts of information and telecommunications law and special acts of the NBU and the Government regulating the architecture of the System, the procedure for connecting subscribers, tariffs, and features of operation in wartime) is justified. It is shown that the centralized hub model of the NBU's BankID, in which the provider does not store or process personal data, is consistent with the GDPR's logic of minimizing processing and separating the roles of data owner and data controller. Based on statistical analysis, the transition from pilot use to large-scale operation of the System has been proven (87.7 million successful identifications in 2024, more than 60% of banks are subscribers-identifiers, with the non-commercial segment dominating), and the key stages in the evolution of the regulatory regime have been identified – from a social e-governance project to a remote onboarding infrastructure in the context of a pandemic and martial law. Conclusions. It is concluded that the NBU's BankID is the institutionalized result of a public-private partnership between the state, the NBU, and the banking sector, and already serves as a functional “bridge” between the Ukrainian and European models of electronic identity. The evolution of the national regulatory framework towards the implementation of eIDAS/eIDAS 2.0, GDPR, the AMLD package of directives, FATF recommendations, and EBA guidelines creates the conditions for further formal validation of the NBU's BankID trust levels and the use of the System as compatible with the European trusted electronic services space, particularly in the segment of remote customer service for EU banks.

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