Handling KYC Updates

What is the KYC update solution?

The KYC update solution enables periodic updates of certain information about your users according to their risk profile, in compliance with regulatory requirements. Available from June 2026.

Why are we implementing this solution?

Regulations require periodic updates of customer information according to their risk profile. This solution automates this process and offers two options (Plug & Play or Manual) to manage communications with your users.

Who is affected by this KYC update?

Users Affected

Natural persons (individual) and legal entities in business relationships with an active payment account:

Marketplace B2B & B2C: Merchants
Marketplace C2C: Sellers
Crowdlending: Lender, Project Holders
Crowdequity: Investor, Project Holders
SVA: Content Editor, Other Operators
Other: Visa Applicants

Users not Affected

Users with technical wallets and users without an active payment account:

Marketplace: Buyers
Crowdfunding: Donors
SVA: Operators
Other: Payer (Visa Application account activity)

Implementation Options

What are the options available for managing KYC updates?

1. Plug & Play Option

Lemonway automatically sends 3 email communications to end users:

Upon update request: 2 months before the deadline date
Upon rejection: if the submitted KYC update is rejected
Upon restriction: if the deadline date is passed without a validated update

Emails use templates configured by Lemonway. If you wish to send additional reminders between these 3 communications or a confirmation email when the update is validated, this can be managed using notifications 53 and 54

2. Manual Option

You manage all communication with your clients. You receive notifications 53 (requirements) and 54 (restrictions) by webhook or email, allowing you to automate the process according to your needs, your reminder schedule, and your brand guidelines.

Can we switch from one option to another after deployment?

Yes. You can start with the Plug & Play option (Lemonway sends emails) and later request Lemonway to deactivate automatic email sending to switch to the Manual option when you are technically ready.

This flexibility allows you to start quickly with the Plug & Play solution while working on your technical integration.

What is the cost of the Plug & Play option?

No additional cost. Both options (Plug & Play and Manual) are included in the Lemonway product at no extra charge.

Lemonway Dashboard and Visibility

What visibility will we have on accounts requiring a KYC update?

Your Lemonway Dashboard will offer complete visibility over all accounts with:

Two distinct columns for requirements and restrictions
Filters to identify accounts by status, deadline, and type of required update
The ability to export all data for your internal analysis and tracking

Can we filter accounts that will require an update in the coming months?

Yes. Your Lemonway Dashboard will allow you to filter and sort accounts according to various criteria, including upcoming deadlines. You will be able to proactively identify accounts requiring action within the next 2 months and plan your communication campaigns accordingly.

How do we know a user's risk level and the associated update frequency?

The risk level is not directly visible in the Dashboard or via the API for confidentiality and data protection reasons. You will have access to:

The KYC update requirement (notification 53)
The deadline for completing the update

Update frequencies according to risk profile (in compliance with regulatory requirements):

Risk Level	Update Frequency
High Risk	Every 12 months
Medium Risk	Every 3 years
Low Risk	Every 5 years

Notifications and Webhooks

Which notifications will inform us of KYC update requirements?

Two new dedicated notifications are available:

Notification 53 - Requirements: Informs you when an account requires a documentary or informational update, without immediate blocking of operations.
Notification 54 - Restrictions: Alerts you when an account is subject to operational restrictions due to a KYC update not being completed within the required timeframe.

These notifications can be received by POST webhook or by email, according to your configuration.

Do these new notifications replace webhook 50 statuses?

Yes. Notifications 53 and 54 replace what was previously planned in notification 50 concerning KYC updates.

Notification 50 will continue to exist for other account status changes, but information relating to requirements and restrictions will now be transmitted only via:

Notifications 53 and 54
The GET/account endpoint, which will return the requirements and/or restrictions objects

When will these new notifications be available?

Notifications 53 and 54 will be available from June 2026, in phase with the general deployment of the new KYC update solution. They will first be accessible in the sandbox for your integration tests.

Do these notifications work for old wallets without an associated account?

Notifications 53 and 54 are dedicated to account-level requirements and restrictions. Notification 8 remains used to share status changes for wallets.

For old wallets without an associated account, Lemonway will manage the creation of accounts or the closure of unused wallets.

Can I receive notifications by email if I don't use the API?

Yes. Notifications 53 and 54 can be configured to be received either by POST webhook (for automation via API) or by email if you manage the process manually.

This flexibility allows you to stay informed of necessary updates regardless of your level of technical integration.

Timelines and Deadlines

Can update deadlines be customised according to our needs?

No. Deployment takes place according to two fixed dates:

July 1st for the Plug & Play option
September 15th for the Manual option

These dates apply to all Lemonway partners and their end users.

Why do deadlines differ between the two options?

For the Manual option, additional time until September 2026 is granted to allow for technical integration on the partner side, while enabling Lemonway to progressively deploy the process in compliance with validation SLAs.

For accounts in high-risk jurisdictions (particularly Monaco), will all accounts need to be recertified?

All accounts are affected by the KYC update. The update frequency, ranging from 12 months to 5 years, depends on the risk level associated with the account holder. This risk level is defined based on a large number of factors, including the holder's country of residence. Being located in a high-risk country, therefore, impacts the customer's risk level.

End User Communications

In which languages will emails be sent to end users?

Lemonway supports the following languages for email communications:

English
French
German
Italian
Spanish

Language determination logic:

Birth country of the individual or legal representative
Country of residence
Partner country

Can we customise the emails sent by Lemonway in the Plug & Play option?

The Plug & Play option offers standardised emails and templates configured by Lemonway.

If you want complete customisation of communications (brand guidelines, tone, content), we recommend choosing the Manual option, which gives you total control of communication with your users while benefiting from notifications 53 and 54 to automate the process.

How do we manage update campaigns if we choose the Manual option?

To effectively manage your campaigns with the Manual option, you will need a comprehensive view, including:

Who to contact: List of affected users
What information to request: Specific missing documents or data
Within what timeframes: Deadlines before restrictions

This information will be accessible via:

Notifications 53 and 54 were sent in real-time
Dashboard filters and exports for an overview
The API for integration into your CRM or campaign management tools

Will it be possible to update a user's contact email via the Lemonway Dashboard or the API?

This functionality is not yet available.

Will translation quality be improved?

We are continuously improving the quality of our translations. Your feedback and suggestions are welcome and will be reviewed in compliance with regulatory requirements.

Documents and Verification

What documents will be requested during a KYC update?

This depends on the changes identified for the user:

For Legal Entities

The same documents as during initial onboarding are required.

For Natural Persons

If no information changes:

No documents are required. The user confirms that their information is up to date.

If information changes:

Documents related to the changes may be requested depending on the information modified.

Note: In certain specific cases, identity verification by liveness may be requested.

Will you provide a definitive and clear list of accepted documents for legal entities?

For legal entities, the documents required during a KYC update are the same as those requested during initial onboarding:

Registration document: Mandatory
Other documents: Optional, depending on the situation

Important: In case of a change of legal representative or beneficial owner, updated documents proving these changes must be provided. Without these documents, the update will be rejected.

What happens when a document expires?

Identity documents of natural persons already validated will not be requested again, even if expired.

Will we have access to updated identity documents and information for legal entities?

Yes. This functionality will be accessible from the deployment of the solution in June 2026.

Restrictions and Blockages

What operations are blocked when an account is subject to restrictions?

By default, all transactions are blocked.

Exceptions are provided for certain profiles to avoid completely interrupting their activity and not jeopardising the situation of their potential counterparties.

Authorised Operations by Profile

Activity	Profile	Authorized Operations
Crowdlending	Lender	Receive P2P transfers (reimbursements, dividends)
Crowdlending	Project Holder	Receive pay-ins and send P2P transfers
Crowdequity	Investor	Receive P2P transfers (reimbursements, dividends)
Crowdequity	Project Holder	Receive pay-ins and send P2P transfers

Onboarding Links

Can you offer multi-use links rather than single-use links?

Links are single-use for security reasons.

How do we regenerate an inactive onboarding link?

The procedure is identical to that of initial onboarding:

If you use the API: Use the /resume endpoint for link regeneration that you have already implemented.

If you use the Lemonway Dashboard: Access the relevant account and regenerate the link directly from the account details.

Can we track expected documents directly from the Lemonway Dashboard?

You will not have access to a clear description of the specific expected documents on your Lemonway Dashboard, as the nature of potentially required documents will depend on the user's profiles (e.g., legal entity, natural person), the information requested, and updated by the user.

Rejection Reasons and Transparency

Will rejection reasons be more precise and actionable than currently?

Yes. Lemonway is working on much more granular and actionable rejection information, both for initial onboarding and KYC updates.

The objective is to allow you and your users to understand precisely what needs to be corrected to accelerate validation. This improvement is planned for the end of Q2 2026.

Processing Times

Will the 48-72h validation times be respected, and how can we track progress?

Lemonway commits to a maximum SLA of 48 hours for manual validation of KYC updates. Some cases will benefit from automatic validation.

Currently, there is no detailed visibility on processing progress. You will receive notifications when the status changes (Under review, Accepted, Rejected).

Migration and Existing Processes

Does this solution concern users who already have an Ondorse re-verification process in progress?

Users with an active KYC update link via Ondorse should continue with this process until completion. The new solution will apply to new update cases required after its deployment.

Shouldn't the migration from wallets to accounts be completed before deploying this new solution?

Yes, this is an essential prerequisite. We are currently working on this migration, which constitutes the first step before being able to deploy the KYC update solution for all our partners.

For partners who want us to manage the creation of accounts associated with wallets, discussions are already underway.

Will technical wallets exist in the future, and will they also require KYC?

Yes, technical wallets will continue to exist for activities and flow schemes for which they are relevant. These wallets do not require prior KYC, and will therefore not require KYC updates.

Can an account incorrectly created as a payment account be reclassified as a technical account?

No. It is not possible to change the type of an account. If an account was created with the wrong type, it must be closed, and a new account must be created with the correct type.

Technical Aspects

When will the API documentation be updated with all technical information?

The documentation will be shared before sandbox deployment to allow you to prepare your developments.

When will the API allowing KYC data sharing with marketplaces for AML compliance be available?

This functionality requires an in-depth study with regulatory and GDPR teams. Lemonway must ensure compliance with applicable regulations while responding to requests from certain local regulators.

User Experience

Will end users be notified when their KYC update is successfully validated?

Lemonway does not send a confirmation email in Plug & Play mode when the update is accepted. If you wish to send this confirmation, you will need to receive the webhook (notification 53 with 'accepted' status) and manage this communication directly with your users.

Even with the Plug & Play option, will we need to integrate elements to track status and display it in our interface?

No, this is not mandatory. In Plug & Play mode, we manage email communications with your end users. However, if you wish to display KYC update information in your interface, you can receive notifications 53 and 54 or consult the API to integrate:

The account status (active requirement, applied restriction)
Requirements by the user
Active restrictions on the account