Every new business customer a financial institution signs creates years of compliance work down the line. According to Duna, reboarding can account for as much as 90% of total compliance volume as a customer base scales, meaning teams increasingly spend more time maintaining existing relationships than winning new ones.
Consider a FinTech with thousands of business customers. Every policy update, regulatory shift or periodic review generates fresh compliance obligations across the entire book. The more customers an institution onboards, the greater its reboarding volume becomes, and the higher the operational cost of managing it.
RegTech firm Duna recently discussed why reboarding has become the biggest challenge in compliance.
Reboarding, also known as re-KYC, is the process of keeping business information accurate and complete throughout the customer lifecycle. Each review builds on data already collected, and several distinct events can trigger one.
The first is time-based, or periodic, reboarding. Customer data is only accurate at the moment it is captured; an ultimate beneficial owner (UBO) may marry and change their surname, gain citizenship elsewhere, or move address. Regulators require firms to periodically confirm whether anything has changed, with cycles set by risk: annually for high-risk customers and every three to five years for low-risk ones.
The second is event-driven reboarding, triggered when a customer’s behaviour departs from their expected profile. A bakery suddenly generating €1m in monthly revenue would prompt a review, as would a shift in media presence or a website that fails to reconcile.
Policy or regulatory changes form a third trigger, where new rules or auditor decisions demand additional data such as financial statements or tax IDs. Finally, product upgrades or downgrades, such as a current account holder adding a mortgage or opening a trading account, alter risk exposure and fund flows, prompting remediation.
The frustration for institutions is that reboarding is purely defensive. In the best case, nothing has changed and the firm is simply protected from regulatory, financial and commercial downside.
In the worst case, 10-15% of customers fail to respond or supply inconsistent data, forcing firms to choose between ending the relationship or accepting the risk.
The problem is compounded by workflow-based KYB systems designed solely for onboarding. When repurposed for reboarding, they break in predictable ways: historical context is lost as workflows change, changes become harder to explain across scattered questionnaires and cases, customers are asked to resubmit information they have already provided, and analysts waste time manually reconciling old and new data rather than assessing genuine risk.
Duna argues a policy-driven approach solves this. Compliance teams define the evidence each customer should have on file, and a policy engine continuously evaluates existing evidence, requests what is missing and routes exceptions to analysts. One large European marketplace uses this model to manage more than 50,000 customers, reboarding 97% of them with partners spending an average of just 11.1 minutes per request, while inactive customers were offboarded.
Brand New Day Bank CCO Bas van Beusekom said, “With Duna’s platform, we confidently onboard and manage business customers from first interaction through the full customer lifecycle.”
When changes are automatically assessed against policy, regulatory updates become routine rather than disruptive, freeing compliance teams to investigate complex cases instead of ticking boxes.
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